In its review of the Finance (Budget) Law for 2017 ({News-2016-12-21/A/2- previous coverage}), the French Constitutional Council (Conseil Constitutionnel) has ruled that the new diverted profits tax (DPT) regime is unconstitutional. The DPT measures were introduced to mainly target large multinationals such as Google to allow the taxation of profits derived from France.
In its review of the DPT provisions, the Court focused on the fact that the tax authority has the power to choose, among ta…