News & Analysis as of

France International Tax Issues

Mayer Brown

Requalification des gains issus de Management Packages en salaires et interposition d'une holding personnelle : nécessité pour...

Mayer Brown on

La Cour administrative d'appel de Paris rejette la requête de l'administration fiscale tendant à la requalification en salaires de gains réalisés par la holding personnelle d’un dirigeant lors de la cession de titres acquis...more

Mayer Brown

Mise à jour de la doctrine administrative relative aux prix de transfert

Mayer Brown on

À la suite de la publication de l’édition 2023 du Guide des prix de transfert à l’usage des PME, l’administration fiscale a mis à jour ses commentaires au BOFiP relatifs aux principes de détermination des prix de transfert...more

Jones Day

France Expanding Tax Permanent Establishment Definition, Overturning Previous Case Law

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The Situation: In December 2020, the French administrative supreme court issued a major decision expanding the permanent establishment ("PE") concept and criteria for both French corporate income tax ("CIT") and value-added...more

McDermott Will & Emery

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

McDermott Will & Emery on

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

McDermott Will & Emery

[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

Skadden, Arps, Slate, Meagher & Flom LLP

Critical Thinking in the Time of COVID-19: What To Consider Next From a European Tax and State Aid Perspective

In this series, “Critical Thinking in the Time of COVID-19,” our European tax practice examines the next stage of analysis for corporates that have begun digesting the economic and legal impact of COVID-19 on their...more

Society of Corporate Compliance and Ethics...

US and France reach agreement on digital tax

Report on Supply Chain Compliance 3, no. 3 (February 6, 2020)  - France has agreed to suspend collection of the Google, Apple, Facebook, and Amazon, or “GAFA” digital tax until the end of the year, allowing for a period of...more

Robins Kaplan LLP

Financial Daily Dose 1.8.2020 | Top Story: Speaker Company Sonos Sues Google for Patent Infringement

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Home speaker maker Sonos has sued Google, accusing the company of “infringing on five of its patents, including technology that lets wireless speakers connect and synchronize with one another.” Sonos had originally partnered...more

Akin Gump Strauss Hauer & Feld LLP

USTR Proposes Additional Duties on $2.4 Billion in French Imports

Key Points - USTR has proposed to impose additional duties of up to 100 percent ad valorem on $2.4 billion in imports of French products in response to France’s Digital Services Tax. - The proposed duties would apply...more

ArentFox Schiff

US Opens A New Front in Trade Wars with Proposed France Duties

ArentFox Schiff on

Parties seeking changes to the proposed list of tariff subheadings or to lower duties should take advantage of this comment period. Why is USTR proposing additional duties on French imports? Under Section 301, USTR can...more

Faegre Drinker Biddle & Reath LLP

U.S. Trade Representative Announces Results of Section 301 Investigation of French Digital Services Tax

The U.S. Trade Representative (USTR) has completed the initial stage of a Section 301 investigation regarding the Digital Services Tax (DST) passed in July 2019 by the French Parliament, which imposes a three (3%) percent...more

Holland & Knight LLP

USTR Initiates Section 301 Investigation into French Digital Services Tax

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• The Office of the U.S. Trade Representative is conducting an investigation under Section 301 of the Trade Act of 1974 with respect to the digital services tax (DST) bill recently approved by the French Parliament. • Under...more

Jones Day

French Parliament Passes GAFA Tax

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On July 11, 2019, the French Parliament adopted the bill creating a tax on digital services, applicable as from January 1, 2019. Failed International Attempts - The desire to adjust tax policy in the digital age is not...more

Faegre Drinker Biddle & Reath LLP

U.S. Trade Representative Initiates Section 301 Investigation of French Digital Services Tax

The U.S. Trade Representative (USTR) has initiated a Section 301 investigation regarding the Digital Services Tax (DST) proposed by the French government, which would impose a three percent additional tax on certain companies...more

White & Case LLP

US Trade Representative Initiates Section 301 Investigation of France's Digital Services Tax

White & Case LLP on

On July 10, 2019, the Office of the United States Trade Representative (USTR) initiated an investigation under Section 301 of the Trade Act of 1974 to determine whether a Digital Services Tax (DST) recently approved by the...more

Womble Bond Dickinson

Be Thankful I Don’t Take It All – France Moves to Tax the Value of Data

Womble Bond Dickinson on

Were the Beatles still recording today, they might have to add this verse to Taxman. As what will surely be the opening salvo in government efforts to find ways to recapture the value of the personal data upon which so much...more

Jones Day

France and Luxembourg Sign New Tax Treaty

Jones Day on

The Situation: On March 20, 2018, the governments of France and Luxembourg signed a new double tax treaty that will replace the current tax treaty dated April 1, 1958 (as amended through 2014). The Result: The most...more

Skadden, Arps, Slate, Meagher & Flom LLP

International Taxation in the Digital Era: The Rapidly Evolving European Perspective

Europe’s politicians worry that international tax rules have not kept pace with the digital economy and too easily allow multinationals to organize their global operations to minimize net taxable profits in high-tax European...more

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