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 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 (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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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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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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1- In France, several provisions of the General Tax Code (« Code Général des Impôts », or « GTC ») and the Tax Procedures Book (« Livre des Procédures fiscales » or « TPB ») regulate the owning of offshore accounts, by measures such as the information of the Administration and the authorization of automatical […]
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