By the court decision of the 31 march 2017 the Council of the State it was admitted the validity of the bare ownership (nue-propriété) donation of the shares under condition of reinvestment and postponement of the unsecured usufruct. By this the supreme judges confirm their position of the 10 February (CE, 9e et 10e ch., 10 févr. […]
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Still an imperfect tax regime (« Plus-values immobilières des non-résidents : un régime d’imposition encore imparfait ») The real estate capital gains tax scheme provided for in article 244 bis of the CGI penalizes foreign companies which own real estate not related to the professional activity in France unlike the French companies. This difference does not seem […]
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The Council of State transmits to the CJEU the next preliminary questions Should articles 56 and 58 of the Treaty establishing the European Community (TEC) – now articles 63 and 65 of the Treaty on the Functioning of the European Union (TFEU) – be interpreted as a cash-flow disadvantage (“désavantage de trésorerie”) resulting from the […]
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French Corporate Tax to the test of European Tax Competition (Impôt française sur les sociétés à l’épreuve de la concurrence fiscale européenne) Since the European Union has become a ground of an intense Tax Competition between State Members to draw the entities and their benefits, the French government seems to have decided to adapt a […]
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The Council of State transmits to the CJEU the next preliminary questions (“questions préjudicielles”): Should articles 56 and 58 of the Treaty establishing the European Community (TEC) – now articles 63 and 65 of the Treaty on the Functioning of the European Union (TFEU) – be interpreted as a cash-flow disadvantage (“désavantage de trésorerie”) resulting […]
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A new project of the law relative to the fight against fraud was submitted As a counterpoint to the project of the law “Confiance”, having an ambition to protect the citizens acting in a good faith in their relations with the administrations, the government has submitted to the Senate (“Sénat”) March 28, 2018 a new […]
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