Objet : Tax audit of the computerized accountings: legal and litigation aspects The regime of the tax audit of the computerized accountings (TACA, French CFCI – contrôle fiscal des comptabilités informatisées) establishes a legal framework convenient to the efficiency of the tax audit. In spite of the apparent complexity of the procedure and the […]
Read more A new procedure for fiscal control, which is an intermediary between the document control and the accounting verification, is introduced. The Administration may thus, when taxpayers compelled to keep and present accounting records keep their accounts by means of computerized systems, examine this accounting without going to the spot after the taxpayers have transmitted to […]
Read more Elimination of double taxation on international flow, which is the main purpose of bilateral tax treaties, is not perfectly achieved in several situations. The recent changes of case-law highlight again the fact that that the solutions found over time concerning elimination of double taxation deserve to be harmonized, under the leadership of the judge, or […]
Read more Have you foreseen to take over a company which is chargeable to corporate tax? Have you thought about another transaction more interesting than a simple corporate buyout: to create a takeover holding? Which benefits? LBO : a common transaction The buy-out by the holding company Today, the usual way to buy-out a company, more precisely […]
Read more It results from the combination of articles L1231-11 and L1237-112 of the French Employment Code (“Code du Travail français”) that the contractual termination of the employment agreement can only intervene as required by the legal rules which regulate this way of termination. Those rules are intended to guarantee the freedom of consent of the parties. This is what the French […]
Read more A fiscal mechanism foresees an exemption for the VAT to which the transfer of an immovable affected by a rental activity is subjected to. I.CASES WHERE THE EXEMPTION IS POSSIBLE: Article 257 bis of the French tax code (“Code general des impôts”) provides a specific mechanism of VAT exemption for an operation undertaken between taxable persons […]
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