Avocats
The French draft Finance Bill for 2020 introduces a new tax residency requirement for executives of major French companies (article 4 B of the French Tax Code). According to the draft measure, officers of companies with headquarters in France and an annual ... read more
The 2019 Finance Act introduced a general anti-abuse corporate tax rule that allows the tax administration to disregard an arrangement or series of arrangements which: i. Having been put in place for the main purpose or one of the main purposes of obtaining ... read more
Since January 1, 2016, individuals whose employment income falls within certain brackets are required to pay the “universal healthcare contribution”, also known as the “PUMA tax”. Prior to January 2019, those required to pay this tax ... read more
After examining a taxpayer’s personal tax situation, the tax administration considered that the transfer of securities at a derisory price, made between members of the same family, constituted a disguised gift. For that purpose, the Court implemented ... read more
In principle, partnerships such as general partnerships (société en nom collectif), limited partnerships (société en commandite simple), civil partnerships or limited liability companies whose single member is an individual (EURL) are not subject to ... read more
Within the framework of the next finance and social security Bill , several reforms are bound to have an impact on taxes in France for non-residents. Overview of the main measures foreseen: Exemption of capital gains tax on sale of main residence after ... read more
For the past several months, French legislators (deputies) have sought to implement a tax break on transfers by gift or inheritance. To this end, last May, legislators introduced a bill mainly aimed at increasing the tax allowance beyond which an ... read more
In a ruling dated 13th June 2018 (CE plén. 13-6-2018 n° 395495), the Council of State has finally clarified the notion of an “active holding company,” which it defines as a company: “whose principal activity, in addition to managing a ... read more

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