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Shares Acquired Upon the Exercise of BSPCEs Now Eligible for Tax Neutrality Regime in Share-for-Share Contribution Cases

On February 5, 2024, the French Supreme Tax Court (Conseil d’État) voided French tax authority guidelines from May 2023 that provided that shares acquired upon the exercise of founder stock options, or Bons de Souscription de...more

International Legal Highlights | June 2022

EUROPEAN COMMISSION ADOPTED A PROPOSAL DIRECTIVE ON CORPORATE SUSTAINABILITY DUE DILIGENCE - On 23 February 2022, the European Commission (EC) adopted a proposal for a directive on corporate sustainability due diligence...more

International News: Spotlight on Tax

INTRODUCTION TO US TAXATION OF NFTS - Despite Non Fungible Token (NFT) sales hitting nearly US$21 billion by the end of 2021, making NFTs almost as valuable as the global art market, they are currently completely ignored...more

An Overview of OECD Pillar 2

The Organisation for Economic Co-operation and Development (OECD)/G20 Global Anti-Base Erosion (GloBE, Pillar 2) Model Rules, published in December 2021, intend to address perceived challenges to long-standing international...more

OECD Pillar 2 Q&A

WHAT IS THE AIM OF PILLAR 2 RULES? The aim of the Organisation for Economic Co-operation and Development (OECD) Inclusive Framework’s project is to ensure that multinational groups of companies pay a minimum level of tax...more

2/14/2022  /  Corporate Taxes , EU , GILTI tax , OECD , Pillar 2 , Tax Rates

Supreme Tax Court Upholds Broad Interpretation of Permanent Establishment, Partially Overturns Protective Google Case Precedents...

In a landmark decision of 11 December 2020 involving digital player Conversant (fka Valueclick), the French Supreme Tax Court (Conseil d’État) ruled that a French company can qualify as a dependent agent, and thus as a French...more

French Withholding Tax on Capital Gains Realized on Substantial Shareholdings by Non-French Companies Ruled Illegal

The French Supreme Tax Court (Conseil d’État) ruled that the French withholding tax on the capital gain derived from the disposal of a substantial shareholding in a French company by a non-resident company is not compliant...more

Special Report - Coronavirus Update - Monitoring of the Main Tax Measures/Subsidies Country-by-Country Overview

The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, North and Latin America quickly evaluating and issuing modified tax-related measures to help support business investments and providing...more

[Webinar] Virtual Tax Forum | Critical Tax Strategies for US MNCs with Operations in Germany, Italy, the UK and France - June 4th,...

Evolving and intersecting tax regimes are creating unintended tax exposure, as well as areas of opportunity, for multinational companies (MNCs) operating in European markets. Understand how new tax regulations transect...more

Special Report - Coronavirus Update - Monitoring of the Main Tax Measures / Subsidies - Country-by-Country Overview

The Coronavirus (COVID-19) has governments across Europe, Asia, Africa, Australia, Latin America and the United States quickly evaluating and issuing modified tax-related measures to help support business investments and...more

Despite Appeals Win, Google Agrees To Eur 1B Settlement To Avoid Criminal Prosecution

The Paris Court of Appeal affirmed that Google Ireland does not have a French permanent establishment in a high-profile tax controversy over a double Irish arrangement. But with independent criminal proceedings for tax...more

International News: Private Equity - December 2019

A recent McDermott round table on European health private equity generated key insights into the future of medtech, digital health, and data analytics, and identified opportunities for companies and investors. Digital...more

The Rise of Digital Services Taxes

Governments are starting to catch up with online businesses. Multinational clients that provide online advertising services, sell consumer data, or run online intermediary platforms should prepare themselves for the imminent...more

Focus on Tax Controversy - Summer 2015

The French 3 Percent Distribution Tax: Claiming a Refund - Since December 2012, French companies have been liable for a 3 percent tax on distributions to their shareholders (3 Percent Tax), but practitioners have widely...more

Focus on Tax Strategies & Developments - March 2015

In This Issue: - U.S. International Tax Policy: 10 Questions for 2015 - The New UK Diverted Profits Tax - France Implements Horizontal Tax Consolidation - China’s New General Anti-Avoidance Rules: An...more

3/5/2015

French Social Taxes: Taxpayers Subject to Social Security Contributions in Another EU Member State Could Claim a Refund

EU resident individual taxpayers who have paid French social taxes (contribution sociale généralisée (CSG), contribution au remboursement de la dette sociale (CRDS) and prélèvements sociaux) on France-originating real estate...more

French 3 Per Cent Tax on Distributions: French Subsidiaries of Foreign Companies Should Consider Claiming a Refund

Scope of The 3 Per Cent Tax - The 3 per cent tax is levied on dividend distributions and/or deemed dividend distributions by French companies, French permanent establishments and other French entities that are liable...more

Filing Obligations for Trusts in France: Annual Filing Deadline One Month From Today on 15 June

The annual filing imposed on trustees must be submitted by 15 June on new, dedicated forms published by the French tax authorities, and in the French language. ...more

France Tightens Disclosure Requirements for Large Companies, Particularly in Relation to Transfer Pricing

The Anti-Tax Evasion Act and the Finance Act 2014 have introduced an annual transfer pricing documentation filing obligation and new disclosure requirements for large companies....more

France: Non-Cooperative States as of 1 January 2014

France’s list of non-cooperative states and territories published in 2013 includes Botswana, Brunei, Guatemala, Marshall Islands, Montserrat, Nauru and, effective from 1 January 2014, Jersey, Bermuda and the British Virgin...more

1/6/2014  /  EU , Tax Evasion

France Adds Jersey, Bermuda, BVI To Black List Of Uncooperative Tax Havens

France’s non-cooperative states and territories list for 2013 includes Botswana, Brunei, Guatemala, Marshall Islands, Montserrat, Nauru, Jersey, Bermuda and the British Virgin Islands (BVI). The tax consequences related to...more

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