France Tax News
Final Report on Improving the Resolution of Tax Treaty Disputes
French Supreme Administrative Court
ECJ: hearing in case regarding Dutch withholding tax on outbound dividends
Guideline on French CFC rules published – details
EU Commission requests Italy not to apply a withholding tax on dividends paid to Netherlands parent companies
EU Commission requests Italy to implement the Interest and Royalties Directive correctly
Protocol to treaty between Japan and France signed
Report on Attribution of Profits to PEs released
Finance Law for 2007 published
EU Commission progresses infringement actions against Member States for discriminatory taxation of outbound dividends
Protocol to treaty between Luxembourg and France signed
ECJ holds French withholding tax on outbound dividends incompatible with freedom of establishment
ECJ: previous UK ACT regime regarding outbound dividends compatible with EC fundamental freedoms (ACT IV GLO) – details
Treaty between France and Switzerland – exchange of notes on pension income published
Application Decree on new CFC legislation published
Protocol to treaty between Luxembourg and France – erratum
Finance Amendment Bill for 2006 adopted by Council of Ministers
French Parliamentary response on non-eligibility of Luxembourg SICARs to France-Luxembourg tax treaty and EC Parent Subsidiary Directive
Guideline on unilateral modification of tax sparing credit not in breach of France–Brazil tax treaty
New protocol to France-US income tax treaty ratified
Finance Bill for 2007 adopted by Council of Ministers – measures for companies
Treaty negotiations between France and Japan finalized
Protocol to treaty between Luxembourg and France – immovable property and business profit provisions amended
European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures
European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends
Treaty between Australia and France – details
European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive
European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid
Guideline on French withholding tax applied to certain interest income published
Treaty between France and Netherlands – Code of Conduct (MAP)
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