Orbitax Tax News & Alerts
France's Tax news & updates from Orbitax and partners
France Tax News
ECJ: Advocate General finds French legislation on group consolidation excluding lower-tier subsidiaries indirectly owned through companies in other Member States justifiable restriction on EC freedom of establishment
Protocol to treaty between France and Malta signed
Treaty between Belgium and France: regular participation in commodity exchange held to be permanent establishment
OECD released 2008 Model Tax Convention
Discussion draft on New Art. 7 of OECD Model – details
Treaty between France and Netherlands – French Administrative Court of Appeal finds withholding taxes applied to Dutch pension funds contrary to treaty non-discrimination clause and EU free movement of capital
Treaty between France and Switzerland – French Supreme Administrative Court holds Swiss resident taxable in France on payments for services performed in France but paid via UK company
OECD Council approves 2008 Model Tax Convention
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax
Treaty between France and United Kingdom – details
Guidelines on group taxation issued
2008 treaty between France and United Kingdom signed
Bill on Economic Modernization
Comments on draft contents of 2008 update to Model Tax Convention published
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details
Preliminary ruling requested from ECJ regarding compatibility of Belgian tax treatment of foreign dividends with EC free movement of capital
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)
Protocol to treaty between Qatar and France ratified
Accession Convention to Arbitration Convention will enter into force for France
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive
Advance ruling on whether foreign company entitled to lower rate of CGT on sale of shares in Indian company
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law
French Law ratifying Accession Convention to EC Arbitration Convention published
Bill to terminate treaty with France adopted by Danish parliament
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