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OECD publishes final BEPS project reports

OECD - October 22 2015 On 5 October 2015, the OECD published its highly anticipated final reports in relation to Base Erosion and Profit Shifting (BEPS). The reports are...

Karl Mah, Jordi Domínguez, David S. Raab, Nicholas J. DeNovio, Diana S. Doyle.


Focus on the new French restrictions applicable to the tax deduction of interest incurred on debt financings contracted in connection with certain leveraged acquisitions

France - January 12 2012 Article 40 of the 4th Amended Finance Act for 2011 introduces new restrictions to the deduction of financial expenses (i.e., mainly interest) for French corporate income tax purposes in cases where the corresponding debt financings can be deemed contracted in relation to artificial acquisitions of shares....

Olivia Rauch-Ravisé, Jérôme Commerçon.


French Finance Act 2012 and 4th Amended Finance Act 2011

France - January 4 2012 The 4th Amended Finance Act for 2011 introduces a specific anti abuse mechanism designed to defeat the artificial allocation to a French corporation of debt in relation to the acquisition of shares of an entity (other than a real estate company) which is not controlled from France....

Olivia Rauch-Ravisé, Jérôme Commerçon.


2011 Finance Law extends French thin capitalization rules to third party loans guaranteed by related entities

France - February 28 2011 French tax rules regarding the deductibility of interest charges paid by holding and operating companies are generally regarded as quite favorable....

Olivia Rauch-Ravisé.


France reinforces its set of tax measures against non-cooperative states

France - February 26 2010 Implementing the recommendations resulting from the G20 summits held in 2009 in a context of deep international crisis, France has reinforced its set of measures aiming at fighting against tax fraud and evasion with the corrective finance law for 20091....

Olivia Rauch-Ravisé, Sonia Reeb-Blanluet.