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Entrepreneurs in the New Economy: Is the Grass Really Greener in Silicon Valley?

23 December 2014 | Newsletters

People are always saying it is impossible start a company in France, especially one involved in new technologies or the internet, because of the unfavorable regulatory and business environment. And entrepreneurs who have already launched their startups dream of nothing more than relocating to the San Francisco Bay Area to escape the fiscal and regulatory uncertainty that reigns in...

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Amendment to the French Luxembourg double tax treaty

28 November 2014 | Newsletters

A new paragraph drafted is added to article 3 of the France-Luxembourg Treaty (the Treaty) providing that the gains derived from the disposal of shares, interest and other rights in a company, a trust or any other entity, the assets or belongings of which are consisting for more than 50...

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Guidelines Published on the Newly Introduced Employers' Contribution on High Remunerations

01 June 2014 | Newsletters

The French tax administration recently published the guidelines on the newly introduced taxation on high remunerations. As a substitute to the 75% personal income highest tax tranche that was invalidated last year by the constitutional court, the finance bill for 2014 introduced a specific contribution to be paid by the...

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Draft guidelines on hybrid instruments online since 15 April 2014

24 April 2014 | Newsletters

Following the vote of the article 212, I b of the French tax code restricting the deduction of interest paid by entities subject to corporate income tax to affiliated entities, in the meaning or the article 39, 12 of the French tax code, that are not subject on these interest to a minimum taxation of at least...

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Profit Sharing and Research and Development Credit

10 April 2014 | Newsletters

In a recent court decision (CE 12-3-2014,n°365875), the French supreme tax court ruled that companies having concluded with their employees an agreement for profit sharing concerning both mandatory and voluntary plans are authorized to add amounts paid to relevant employees pursuant to such plans to the compensation taken into consideration in the computation basis for the Research and...

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What is the impact of the asset stripping rules on French private equity firms?

01 March 2014 | Newsletters

In the wake of the financial crisis, the European Commission underscored the responsibility that managers of Alternative Investment Funds (AIFs) have in administering assets and the influence that they can exert on markets and on the companies in which they invest. On the pretext of reducing risks, the Commission proposed rules to limit specific risks arising from the activities...

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