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Legal news

Bare ownership

Posted on : November 22, 2017

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. […]

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Deductibility of the loan and acquisition interests on the bare ownership on the part of the property society

Posted on : November 16, 2017

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 […]

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Economic substance and abuse of rights: tax realism at all costs?

Posted on : November 10, 2017

Economic substance became a central notion in the struggle against a tax fraud and tax evasion, a consensus seeming to have been found by the authorities to make a new reference norm in the field. This article aims to demonstrate in which aspects the use of this notion is superabundant, at best, and a source […]

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Luxembourg life insurance in financial management

Posted on : October 20, 2017

Luxembourg life insurance (l’assurance-vie luxembourgeoise) in financial management Usually called “Luxembourg life insurance” (l’assurance-vie luxembourgeoise), life insurance contract (or a contract of the capitalization) put on the market by the insurance companies located in Luxembourg, has a great success in Europe and especially in France (the first country collector with 30% of purchase). Substantially and […]

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The gains from the equity investment and other shares held on long term should not be included in the added value of the venture capital company or society of capital-investment

Posted on : October 13, 2017

For the application of the article 1647 E of the General Taxation Code of France (CGI) which had as an aim took into account a contributive capacity of the company according to their activity, the venture capital companies as the societies of capital-investment were subjected to the calculation mode of the added value provided by […]

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Overview of French trust

Posted on : September 15, 2017

1. The conditions for the recognition in France of the effects of a trust validly constituted abroad The French jurisprudence recognizes the validity of trusts constituted abroad according to the principle of the autonomy of the will which allows the parties to submit their act to a law knowing the mechanism of the trust. Recognition […]

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