The French Administrative Supreme Court issued a judgment in February that clarifies the assessment of company residence for access to double tax treaty (DTT) benefits, as Nicolas Duboille and Clément Riccio of Sumerson explain.
Further to recent case law, Nicolas Duboille and Hugo Levit of Sumerson, discuss the potential use of alternative legally bound tools in the context of management packages that may be efficient from a tax and social contribution perspective.
Nicolas Duboille and Hugo Levit of Sumerson examine the taxation of real estate capital gains in France by non-residents and consider a case when the seller is a Delaware corporation.
Nicolas Duboille and Alexia Dal Ponte of Sumerson examine the French special expatriate tax regime enshrined in Article 155B of the French Tax Code, in the light of recent case law.
Nicolas Duboille and Hugo Levit of Sumerson analyse why the judges overturned the decision of the Paris Administrative Court of Appeal and ruled in favour of a broad interpretation of ‘dependent agent’.
Nicolas Duboille and Alexia Dal Ponte of Sumerson analyse recent case law concerning the application of the French capital gain tax applicable to non-resident entities on the transfer of a significant shareholding in a French entity.
