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Taxation rules for dividends paid between tax group members are changing

02 December 2015 | Newsletters

Dividends received by a parent company in respect of its shareholdings of 5% or more in other subsidiary companies are exempt of taxes, subject to a 5% tax income inclusion corresponding to costs and expenses relating to such shareholdings. Upon payment of dividends between companies member of the same tax...

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Participation exemption: changes to come?

04 September 2015 | Newsletters

With a decision dated 2 September 2015 (Arrêt CJUE C-386/14, Affaire Steria), the European Court of Justice has ruled that the difference in the tax treatment of dividends received from 95% or more subsidiaries whether established in France or in another European member state is not consistent with the freedom of establishment principle as provided in the European treaties. In application of...

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Implicit Guarantee

17 July 2015 | Newsletters

French case law seems to accept that the interest rate charged between entities of the same group be influenced in certain circumstances by the implicit guaranty reflecting the implied support from other related entities. This concept derived from foreign case law is not without raising questions and difficulties. The exact...

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Publication of abusive tax planning - Summary by Denis Fontaine-Besset

13 April 2015 | Newsletters

The French tax administration (FTA) has just released on the official portal of the ministry for Finance a list of transactions considered as potentially abusive. The official message is to encourage tax payers part of such schemes to enter in contact with the authorities and regularize their tax situation. Nothing is said on the possibility to mitigate penalties,...

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Hamon Law - Obligation to provide prior information to employees : more questions than answers...

13 February 2015 | Newsletters

Obligation to provide prior information to the employees of SMEs in the event of the sale of a company or on-going concern: there are more questions and discussions than answers … In France, the law of 31 July 2014 relating to the social and solidarity economy (the “ESS law” or...

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Finance Bill 2014

06 January 2015 | Newsletters

Further to recent decisions made by the French constitutional court, the provisions of the finance bill for 2015 and the modifying finance bill for 2014 are now definitive. The main provisions concerning companies are summarized below: Finance bill for 2015 Transfer pricing documentation Amounts for penalties applicable in case of default...

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