This annual filing requirement is the last part of an increasingly stringent body of rules that aims at defeating tax optimization schemes that the French Tax Authorities (the “FTA”) consider as excessive and responsible for the reduction of the tax base in France. Article 223 quinquies B of the French Tax Code introduced by Article […]
Management packages have developed with the rise of LBO deals. They serve as an incentive to managers – keys persons to the success of a LBO deal – by enabling them to have a stake in the capital and, therefore, to benefit from an exit capital gain, in conditions that are generally relatively favorable. For […]
For the first time, the Conseil d’Etat (French Supreme Administrative Court) has, in a decision rendered on November 20, 2013[1] , confirmed that the tax treaty entered into between France and Switzerland for the avoidance of double taxation in respect of income tax and wealth tax (hereinafter the “Tax Treaty”) prohibits applying to Swiss residents […]
During his closing speech at the Assises de L’entrepreneuriat (i.e. meetings and talks which discussed entrepreneurship in France) on April 29, 2013, French President François Hollande announced a series of measures in favor of businesses. Such measures have a three-fold objective: stimulate entrepreneurship and mobilize all talents, foster the growth and development of businesses and […]
By nullifying the so-far applied administrative doctrine, the Conseil d’Etat (France’s Highest Administrative Court) has just modified the calculation of mandatory profit-sharing. In the case at hand, the company Schlumberger challenged the calculation of the special mandatory profit-sharing reserve according to the legal formula determined by the administrative doctrine published by the French General Tax […]
The French Accounting Standards Authority (Autorité des normes comptables) has published a note specifying that the amount of the Competitiveness and Employment Tax Credit (Crédit d’Impôt pour la Compétitivité et l’Emploi, hereinafter “CICE”) should be recorded in the credit side of a dedicated sub-entry of the expenditure accounting entry line n°64 – “staff-related expenses”. The […]
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