FILE : Withholding: last line-item! According to recent polls, it seems expected by a majority of the French, the reform of withdrawing is not favorable with business leaders. And for reason ! Who looks forward to, without counterpart, playing the ro...
Deductibility of the loan and acquisition interests on the bare ownership (nue-propriété) on the part of the property society (SCI): a missed appointment for equalizing harmonization On the combined legal basis of the articles 8, 13, 1o и 31,I, 1o, d...
The status of financial investment adviser (FIA), established by the law of 1st August 2003 is aimed at the reinforcement of protection of investors by better regulation of issues related to its activities. Thus, all FIAs fall under a certain number ...
Luxembourg life insurance (l’assurance-vie luxembourgoise) in financial management Usually called “Luxembourg life insurance” (l’assurance-vie luxembourgoise), life insurance contract (or a contract of the capitalization) put on the market by the ins...
On the combined legal basis of the articles 8, 13, 1o и 31,I, 1o, d of the General Taxation Code of France (CGI) the loan interests are acquired personally by the holder of the bare ownership(nue-propriété) to finance the acquisition of the bare owne...
By the court decision of the 31 march 2017 the Council of the State it was admitted the validity of the bare ownership (nue-propriété) donation of the shares under condition of reinvestment and postponement of the unsecured usufruct. By this the supr...
Still an imperfect tax regime (« Plus-values immobilières des non-résidents : un régime d’imposition encore imparfait ») The real estate capital gains tax scheme provided for in article 244 bis of the CGI penalizes foreign companies which own real es...
The Council of State transmits to the CJEU the next preliminary questions Should articles 56 and 58 of the Treaty establishing the European Community (TEC) – now articles 63 and 65 of the Treaty on the Functioning of the European Union (TFEU) &...
French Corporate Tax to the test of European Tax Competition (Impôt française sur les sociétés à l’épreuve de la concurrence fiscale européenne) Since the European Union has become a ground of an intense Tax Competition between State Members to draw ...
The Council of State transmits to the CJEU the next preliminary questions (“questions préjudicielles”): Should articles 56 and 58 of the Treaty establishing the European Community (TEC) – now articles 63 and 65 of the Treaty on the Functioning ...
A new project of the law relative to the fight against fraud was submitted As a counterpoint to the project of the law “Confiance”, having an ambition to protect the citizens acting in a good faith in their relations with the administrations, the go...
Administrative comment on the matter of two exceptional contributions applicable to the financial year from 31 December 2017 to 30 December 2018. In this comment on two new contributions based on the corporate tax (“IS”) of the entities performing re...
