Tax Alert

Taxand indirect Tax update Thursday, September 28th 2017

Taxand's Global Indirect Tax service line provides an update on VAT and indirect tax issues from around the world. Non-UK businesses claiming UK VAT refunds face more perils than in any other EU...
At the request of Arsene Taxand, The French Supreme court has just been asked by an administrative Court about a constitutional question, regarding the compatibility of the 3% tax on dividends to the...
The National Assembly adopted last Thursday the 4th Amendment to French-Luxembourg double tax treaty. The vote of the Senate – which will only be a formality - is scheduled on December 16th....
The new France-Luxembourg double tax treaty will not be voted in time by the Parliament to enter into force in 2016. As a consequence, its effects should be postponed to January 1st, 2017.  ...
In its judgment of September 2nd answering the question referred for a preliminary ruling by the Administrative Court of Appeal of Versailles in a decision of July 29th, 2014 (12VE03691, Groupe...
In September 2014, an amendment to the double tax treaty has been signed between France and Luxembourg. The objective of this amendment was to modify the rules on taxation of capital gains resulting...
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Taxand indirect Tax update
28 Septembre 2017
Taxand's Global Indirect Tax service line provides an update on VAT and indirect tax issues from around the world. Non-UK businesses claiming UK VAT refunds face more perils than in any other EU
The challenged compatibility of the 3% tax on dividends regarding the French Constitution
12 Avril 2016
At the request of Arsene Taxand, The French Supreme court has just been asked by an administrative Court about a constitutional question, regarding the compatibility of the 3% tax on dividends to the
Arsene Taxand - Real Estate
The French National Assembly adopted the 4th Amendment to French-Luxembourg double tax treaty!
15 Decembre 2015
The National Assembly adopted last Thursday the 4th Amendment to French-Luxembourg double tax treaty. The vote of the Senate – which will only be a formality - is scheduled on December 16th.  &
Arsene Taxand - Real Estate
One-year suspension for the Amendment to France-Luxembourg double tax treaty
19 Novembre 2015
The new France-Luxembourg double tax treaty will not be voted in time by the Parliament to enter into force in 2016. As a consequence, its effects should be postponed to January 1st, 2017.  
Arsene Taxand - Tax audit & litigation
The French partial taxation of costs and expenses related to dividends received from European subsidiaries outside France constitutes a restriction on the freedom of establishment
23 Septembre 2015
In its judgment of September 2nd answering the question referred for a preliminary ruling by the Administrative Court of Appeal of Versailles in a decision of July 29th, 2014 (12VE03691, Groupe Steria
Arsene Taxand - Real Estate
The Luxembourg Government has just introduced a bill in Parliament in order to ratify the fourth amendment to the France-Luxembourg double tax treaty
24 Juin 2015
In September 2014, an amendment to the double tax treaty has been signed between France and Luxembourg. The objective of this amendment was to modify the rules on taxation of capital gains resulting f
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The last decade in transfer pricing: nothing has changed but everything
23 Avril 2015
10 years ago, transfer pricing was esoteric area for an isolated group of practitioners. It was perceived as an obscure technical matter only required for tax departments of multinationals. 10 yea
Arsene Taxand - Real Estate
New protocol to the French-German tax treaty: consequences for real estate investors
9 Avril 2015
On March 31st 2015, France and Germany Ministers of Finances signed a new protocol to the double taxation treaty entered into between both countries.   The protocol sets forth new provisions
Arsene Taxand - Real Estate
EUCJ 26 February 2015: No more cumulative application of social security contributions to patrimonial-sourced income between EU Member States
27 Fevrier 2015
Patrimonial sourced income of French residents is subject to social security contributions.                  &
Arsene Taxand - VAT & Indirect Taxes
OECD draft international VAT/GST guidelines on place of taxation
23 Fevrier 2015
On 18 December 2014, the OECD published a discussion draft for public consultation on the international VAT/GST guidelines, focusing on the guidelines on place of taxation for business-to-consumer sup
Arsene Taxand - Corporate Tax management
New restrictions to the application of the parent-subsidiary regime provided by the Amended Finance Bill for 2014
22 Decembre 2014
The French Parliament adopted the Amended Finance Bill for 2014 which encompasses provisions whose purpose is to limit the scope of the parent-subsidiary regime. Two specific amendments should be ca
Arsene Taxand - Tax audit & litigation
Recent cases could lead to the reimbursement of some taxes levied on certain French-sourced income realized by non-residents individuals
15 Decembre 2014
  Two recent cases, one recently ruled by the French administrative Supreme Court (or so-called Conseil d’Etat), and one currently examined by the EUCJ, call into question several provisions of
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Arsene Taxand - Real Estate
Date of application of the 4th Amendment to the Tax Treaty between France and Luxembourg postponed to January 1st 2016
27 Novembre 2014
The Luxembourg Government announced that the law approving the 4th Amendment to the Tax Treaty between France and Luxembourg will be discussed by the Luxembourg Parliament in early 2015. As a conseque
Arsene taxand - Corporate Tax Management
Upcoming French tax group reform will allow horizontal tax consolidation
14 Novembre 2014
Following a European Commission decision, France has amended its rules on allowing horizontal tax consolidated groups. Taxand France summarises the main aspects of this new proposal. A French ta
Arsene Taxand - Tax audit & litigation
Dividends received from subsidiaries in other EU Member States: Neutralization of the 5% lump sum?
10 Octobre 2014
The French tax consolidation regime consists in computing the taxable income of a group of French companies by the sum of the income of companies belonging to the group and by neutralizing some of the
Arsene Taxand - Real Estate
Fourth amendment to the France Luxemburg treaty signed by both countries
8 Septembre 2014
A press release issued on September 5th, 2014 by the Ministry of Finances of Luxemburg announced that a fourth amendment to the double tax treaty in force between France and Luxembourg has been signed
arsenetaxand-tax audit & litigation
Horizontal integration: something new on the horizon
17 Juin 2014
The various European tax consolidation regimes, consisting in assimilating a group of companies to a single company, are relentlessly being criticized by the European authorities. Like the modificatio
Arsene Taxand - Transfer Pricing
New French obligations on transfer pricing in perspective
24 Juillet 2013
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Arsene Taxand - Transfer Pricing
Change in French transfer pricing regulation is expected
17 Juin 2013
By disclosing a report released in March 2013 by the General Finance Inspection (“Inspection Générale des Finances”), the French Ministry of Finance announces its intention to amend the French tr
Arsene Taxand - R&D
How to maximise your research credit
14 Juin 2013
At this time of year the focus is on preparing tax returns and computing research tax credits, therefore claiming all qualifying research expenses is critical to reducing tax liability and gaining an
Arsene Taxand : Best Transfer Pricing team in France in 2013 by International Tax Review
27 Mai 2013
For the second year in a row, the Arsene Taxand Transfer Pricing department has been awarded “Best Transfer Pricing Team” in France by International Tax Review on May 15<sup>th</sup>.<b
Taxand honoured with six awards at the ITR Europe awards 2013
21 Mai 2013
Taxand, the world’s largest organisation of tax advisors to multinational businesses, has been awarded ‘European Indirect Tax Firm of the Year’ for the third time in four years by the International Ta
Arsene Taxand – Tax audit and litigation
Audit of computerised accounting: introduced by the Amending Finance Law for 2012, prevention and reactions
5 Fevrier 2013
Article 14 of the Amending Finance Law for 2012 changed the system for representing accounting documents in dematerialised form to a mandatory system that no longer gives the taxpayer a choice on the
Arsene Taxand - Corporate Tax Management and Strategy
The French Financial Transaction Tax
3 Aout 2012
The amending finance bill for 2012 (“the Bill”) that should be enacted into law in the coming days would amend the French Financial Transaction Tax (“the FTT”).      Brief overview
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Arsene Taxand - Real Estate
Luxembourg and Germany sign new tax treaty, when it will be time for France?
27 Avril 2012
In our previous Tax Alert dated on February 3, 2012, we highlighted the point that the French Tax Administration (FTA) contemplated to renegotiate the French-Luxembourg tax treaty and notably the prov
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