The present French Tax Update will be two-fold. We will first take the opportunity of the Panama Papers leak to look over the French list of so-called non-cooperative jurisdictions and the corresponding tax rules applicable to payments and investments made in such jurisdictions. As usual, we will also comment on several significant decisions issued by French tax courts (including inter alia the application of transfer pricing principles to an exclusive distribution agreement, the compliance with the Constitution of the allowances for holding period under the personal income tax regime for capital gains and the exemption from such 3 percent tax for buybacks of shares), as well as recent publications made by the French tax authorities (in relation to transactions generally viewed as abusive by the tax audit services) and the European Union Commission (in relation to its VAT Action Plan).
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Focus on Non-Cooperative Jurisdictions and Recent Tax Publications
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