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Transfer of profits out of France to a country where they benefit from a more favorable taxation further to a business restructuring

France - April 13 2015 Pursuant to Article 57 of the French Tax Code, profits unduly transferred abroad by a company to other related companies shall be added back into its…

Caroline Silberztein, Eric Meier, Guillaume Le Camus, Hervé Quéré, Veronique Millischer.

Abuse of a double tax treaty through the interposition of a structure hiding the beneficial owner of a royalty

France - April 13 2015 Royalties paid by a company established in France to a foreign person are liable to a 331/3 % withholding tax (of the gross amount). This rate is…

Caroline Silberztein, Eric Meier, Guillaume Le Camus, Hervé Quéré, Veronique Millischer.

Abuse of the territorial rules of gift taxes

France - April 13 2015 Gifts of shares between non resident donor and donees are subject to French gift taxes only when they concern shares in French company. Scheme in…

Caroline Silberztein, Eric Meier, Guillaume Le Camus, Hervé Quéré, Veronique Millischer.

No French VAT on internet sales

France - April 13 2015 Distant sales carried out by a businesses established in other EU member states to French private individuals are subject to French VAT when the…

Caroline Silberztein, Eric Meier, Guillaume Le Camus, Hervé Quéré, Veronique Millischer.

Management packages

France - April 13 2015 Certain employee benefit plans are specially regulated and subject to adapted tax and social regime. Scheme in place: Certain groups propose to their…

Caroline Silberztein, Eric Meier, Guillaume Le Camus, Hervé Quéré, Veronique Millischer.