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"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

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

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

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

Financial Services Regulatory Group bulletin - October 2014

  • McCann FitzGerald
  • -
  • European Union, Ireland, Russia
  • -
  • October 21 2014

The global payments sector continues to evolve, driven by technological advances and changing consumer preferences. The provision of payment services

Keep your collection away from the collectors: tax planning for fine art

  • Baker & Hostetler LLP
  • -
  • USA
  • -
  • October 20 2014

Appreciation of fine art can create challenging tax issues, but with proper planning collectors can minimize the estate, gift, and income tax

Tax Court: mini storage not a “small business”

  • Dentons
  • -
  • Canada
  • -
  • October 20 2014

The small business deduction ("SBD") is a tax-preference provided to certain privately-held Canadian corporations, and only in respect of certain