The French tax administration published Guideline 14 H-1-07 of 2 August 2007 on the application of CFC legislation to long-term capital gains (as defined under French tax law) realised by the foreign CFC and deemed distributed to the French parent company. Details of the Guideline are summarized below.
(a) Background. The Finance law for 2005 substantially amended the French CFC legislation set out in Art. 209B of the French Tax Code (Code Général des Impôts (CG…