France Tax News
Bill ratifying Accession Convention to EC Arbitration Convention submitted to French Parliament
Treaty between Australia and France ratified
Protocol between Argentina and France ratified
Administrative Court of Appeals of Paris decision – whether withholding tax on immovable property gains derived by non-residents compatible with treaty between France and Greece (non-discrimination) and EC law (freedom of establishment)
OECD releases revised draft of Part IV (Insurance) of the Report on Attribution of Profits to Permanent Establishments
Compatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ
Clarification on application of CFC legislation published
ECJ: Interprets anti-avoidance clause under the Merger Directive with respect to Danish rules on taxation of exchanges of shares – details
EU Commission refers Greece to ECJ concerning discriminatory taxation of dividends
EU Commission progresses infringement procedure against Austria, Germany, Italy and Finland regarding taxation of outbound dividends
Second Guideline on implications of ECJ Denkavit case on French dividend withholding tax published
ECJ: Finnish group contribution regime compatible with EC Law – details
Treaty between Luxembourg and France – Luxembourg Administrative Court rules income of Luxembourg SA from French real estate owned by French SCI taxable in Luxembourg
ECJ: German thin capitalization rules reclassifying interests paid to substantial shareholders in third States are not incompatible with EC law
ECJ: Swedish legislation on dividend tax relief in relations with third countries is compatible with EC law – details
ECJ: Advocate General holds German switch-over provision for low-taxed passive income of foreign PEs incompatible with EC Law – details
ECJ: Advocate General finds Dutch withholding tax on outbound dividends incompatible with EC free movement of capital – details
ECJ: Previous Austrian rules discriminating dividends received from third countries are compatible with free movement of capital under grandfathering clause – details
Guideline on implications of ECJ's Denkavit case on French dividend withholding tax published
Treaty between France and UK – Court of Appeals of Paris rules on agency permanent establishment
Tax measures to be included in Finance Bill for 2008 disclosed
Discussion draft on application and interpretation of non-discrimination article of OECD Model – details
Decree published on entry into force of protocol extending EC Arbitration Convention
International tax conference on CCCTB held in Berlin
Report by French group of experts on the Societas Europaea (SE) published
Preliminary ruling requested on compatibility of French participation exemption with Parent-Subsidiary Directive
Revised Commentary on Article 7 of OECD Model released
ECJ: temporal effects of judgment in Meilicke against Germany should not be limited – details
Treaty between France and Switzerland – exchange of notes on dividends (Swiss-EU Agreement)
Company tax regimes of Swiss cantons exempting foreign profits incompatible state aid under EU-Switzerland Agreement
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