The French tax authority has published guidelines on the anti-abuse rule introduced by the Finance Law for 2019 that applies for taxes other than corporate income tax. The rule was introduced along with the general anti-avoidance rules (GAAR) of the EU Anti-Tax Avoidance Directive (ATAD). For corporate income tax, the new GAAR applies from 1 January 2019, while the new anti-abuse rule for other taxes applies from 1 January 2020.
The new rule is provided in Article L. 64 A of the Tax Proced…