On 16 January 2007, the French tax administration published a lengthy Guideline (4H-1-07) on controlled foreign company (CFC) rules. The Guideline covers (i) the definition of a CFC and a low-tax jurisdiction, (ii) attributed income, (iii) the interaction with tax treaties, (iv) double taxation relief and (v) safe-harbour rules.
Background
The French CFC rules set out in Art. 209B of the CGI were substantially amended by Art. 104 of the Finance Law (Law 2…