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Results: 1-10 of 131

Trademark royalties: French tax administration fails to prove indirect transfer of profits abroad

  • Baker & McKenzie
  • -
  • France
  • -
  • November 18 2014

Non-profitable exploitation of a brand does not necessarily mean that it lacks use value. The company Aquarel Europe (now known as Nestlé

Real estate capital gains realized by non-EEA residents: the one third withholding tax can be reclaimed!

  • Baker & McKenzie
  • -
  • European Union, France
  • -
  • November 14 2014

In a decision dated 20 October 2014 (CE n367234, SCI Saint-Etienne), the French Administrative Supreme Court confirmed that the withholding tax

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

"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

Deduction by a French branch of a tax paid in the United Kingdom allowing a tax credit in Portugal

  • Baker & McKenzie
  • -
  • France, United Kingdom
  • -
  • October 22 2014

The Montreuil Administrative Court ruled on the hitherto unanswered question of whether the French branch of a Portuguese company could deduct a tax

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

Compensation for loss of goodwill and unjust enrichment

  • Baker & McKenzie
  • -
  • France
  • -
  • December 31 2012

The loss of goodwill resulting from the termination of a retail distribution contract may not give rise to the application of unjust enrichment rules. In

Abrupt termination and intuitu personae

  • Baker & McKenzie
  • -
  • France
  • -
  • March 28 2013

Unless a contractual termination clause targets this situation, the disposal of all the shares in a company leading to a change in management does not

Free allocation of the tax burden in tax consolidation regime: the last episode

  • Baker & McKenzie
  • -
  • France
  • -
  • December 31 2013

In two decisions dated 5 July 2013, the French Administrative Supreme Court has ruled that tax consolidation agreements under which a parent company

French tax authorities fail in an attempt to characterise a commissionaire as a dependent agent PE

  • Baker & McKenzie
  • -
  • France
  • -
  • July 31 2014

A recent decision clarifies certain issues concerning permanent establishment status and more precisely the notion of dependent agent PE. In this