Legal news

The trusts continue to give a hard time to the tax payers, as well as to the practitioners, and, even though, now it really exists in a French Tax Law, there are a lot of uncertainties rest concerning number of issues. This law concept is polymorph and it brings all the difficulties that we face […]

Generally moved aside by the International Convention Against Double Taxation – or reduced to 5% or 10% for the royalty tax, the withholding, provided by the article 182 B of the French General Tax Code (CGI) for the services remunerations, rendered by the non-residents is applied at the full rate in the absence of the […]

A Fixed Place of Business (établissement stable) and a Veiled Real Estate Activity (activité immobilière occulte): the interesting details by the Council of State in the Frame of the French-Luxembourg convention By the two decisions of the 17 March 2017, the Council of State gave a ruling on the notion of a Fixed Place of […]

Facing an emergence of the rivals, the life insurance loses progressively its «Swiss knife » status of the investments world. STRATEGY It is a continues love story. The French people adore life insurance. Frankly speaking, because the investment offers an unequal status in terms of the capital transmission and allows to make investments on funds […]

Bare ownership (nue-propriété) donation of the shares under condition of reinvestment and postponement of the unsecured usufruct 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. […]

Deductibility of the loan and acquisition interests on the bare ownership (nue-propriété) on the part of the property society (SCI): a missed appointment for equalizing harmonization. On the combined legal basis of the articles 8, 13, 1o и 31,I, 1o, d of the General Taxation Code of France (CGI) the loan interests are acquired personally […]