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Legal news

Application of the long-term capital gains regime to securities not recorded on the balance sheet

Posted on : February 16, 2018

Application of the long-term capital gains (“plus-values à long terme”) regime to securities not recorded on the balance sheet Securities not recorded in the balance sheet may benefit from the long-term capital gains regime, provided that they qualify as fixed assets by their nature and are sold after a period of retention of two years. Council of […]

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Income strategy based on life-insurance

Posted on : January 19, 2018

Despite an uncertain financial environment and a dense and complex legislation, the life insurance remains in 2017 the first financial investment for French. Indeed, this one still represent an excellent technique of current income optimization, and a great means of future income incorporation, gathering liquidities and relative safety. 1- Despite the doubts raised by the […]

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The delicate question of the tax treatment of the incomes of trust

Posted on : December 22, 2017

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 […]

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Withholding tax under article 182 B to the test of the equality principle and the right of defence.

Posted on : December 19, 2017

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 […]

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the interesting details by the Council of State in the Frame of the French-Luxembourg convention

Posted on : December 15, 2017

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 […]

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How to restructure own capital

Posted on : December 8, 2017

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 […]

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