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Results: 1-10 of 4,821

"Coquillards" schemes: the French Administrative Supreme Court's decision on June 23, 2014, 9th and 10th subsect., No. 360708, min. V. Sté Groupement Charbonnier Montdidérien

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

In June 23, 2014 decision, the French Administrative Supreme Court confirmed and clarified the recent position taken in the Garnier Choiseul Holding

Merger of assets involving revalued shares: application of the Quemener case

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

A Luxembourg société anonyme (public limited company) sold to a French company (hereinafter the “Company”) all the shares of 7 Luxembourg sociétés

French tax authorities have finally published their final guidelines on the legal definition of a change of activity

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

More than a year after the tax authorities' first guidelines on the definition of a change of activity provided in Article 221-5, as amended by the

Fight against tax optimization involving hybrid Instruments and artificial debt: administrative comments on the new limitation to the deductibility of interest paid to a related company and new EU directive amending the parent-subsidiaries directive

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

The 2014 Finance Act enacted a new limitation to the deductibility of loan interest paid to a related company by a French company subject to

Liquidators' remuneration and expenses - value-based remuneration and closer scrutiny of expenses

  • Baker & McKenzie
  • -
  • Australia, United Kingdom
  • -
  • October 23 2014

On 25 July 2014 and 17 September 2014 respectively, Justice Brereton of the Supreme Court of NSW delivered two related judgments in Re AAA Financial

VAT, Head-Office and Branch : the Skandia America Corp Case, c-713 - ECJ, 17092014

  • Baker & McKenzie
  • -
  • European Union, France
  • -
  • October 23 2014

The case concerns the VAT treatment applicable to services charged by the foreign office of a company to its branch based in Sweden which is a member

Research Tax Credit ("CIR") and expenses incurred by a subcontractor: the Montreuil Administrative Court stakes out contradictory positions

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

In two separate decisions (no. 1207416, November 29, 2013, and no. 1307130, July 1, 2014, Altran Technologies SA), the Montreuil Administrative Court

VAT compliance - electronic filing and payment

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

The requirement of filing VAT return and pay VAT electronically has been extended to all taxpayers, regardless of turnover as of 1 October 2014

Accuracy of comparables in profit transfers

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

In a decision dated July 8, 2014, the Versailles Administrative Court of Appeal reiterated the requirement for the tax authorities to use relevant

French nationals residing in Monaco may be subject to social taxes in France

  • Baker & McKenzie
  • -
  • France
  • -
  • October 23 2014

In a decision on June 11, 2014, the French Administrative Supreme Court held that a French national residing in Monaco may be subject to social taxes