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Searching Content indexed under Corporate Tax by Jones Day ordered by Published Date Descending.
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1
French Tax Update - Recent Case Law And Other Noteworthy Publications
Literally "not twice in the same," non bis in idem is basically a legal doctrine whereby no legal action can be initiated twice for the same course of action.
France
5 Feb 2016
2
French Tax Update: Draft Finance Bill For 2016, New France/Germany Double Tax Treaty, And ECJ Steria Decision
This French Tax Update will focus on (i) the main provisions of the draft Finance Bill for 2016 issued by the French Government on September 30, 2015 and to be discussed before the French Parliament between October and December, (ii) the amendment signed in March 2015 in respect of the France/Germany double tax treaty, and (iii) the decision issued in early September by the European Court of Justice in the Steria case.
France
9 Oct 2015
3
French Tax Update - Main French Tax Rates For 2015
This special French Tax Update provides an overview of the main tax rates applicable in France.
France
9 Sep 2015
4
Form Vs. Substance
The FTA had denied the Exemption on the basis of the so-called "abuse of law" procedure, i.e., that the Sub had no other purpose than to "transform" taxable income into quasi tax-exempt dividends.
France
20 Aug 2015
5
Abnormal Act Of Management
The decision is a good indication that, other than under exceptional circumstances, the FTA is not supposed to meddle in the daily business decisions of taxpayers.
France
20 Aug 2015
6
Intragroup Reorganization And Abuse Of Law Theory
In 2000, the head of the French tax grouping (Parent) sold to its subsidiary in charge of financial matters and inactive participations (FinCo) the shares of an inactive subsidiary (Sub).
France
20 Aug 2015
7
French Tax Update - Recently Published Noteworthy Decisions - July 2015
The present French Tax Update will focus on an overview of several noteworthy French tax court decisions issued during the past few months.
France
7 Jul 2015
8
IRS Says FDA Consent Decree Payment Is Not A "Non-Deductible Fine" Or Similar Penalty For Tax Purposes
The IRS recently released a field attorney advice memorandum stating that the amount a company paid to the United States to disgorge profits is not considered a non-deductible fine or similar penalty for tax purposes.
United States
10 Jun 2015
9
Exceptional Depreciation Of Industrial Assets
The Exceptional Depreciation will not be reflected under the French GAAP and will take the form of a tax adjustment to book entries.
France
4 Jun 2015
10
Exit Tax On Eligible Assets That Become Subject To The French Reit-Like Regime
Considering that such provisions had never been reviewed by the Conseil constitutionnel and could potentially create a breach of equality between taxpayers, the Conseil d'Etat requested a QPC from the Conseil constitutionnel.
France
4 Jun 2015
11
Retroactivity Of The Limitation On The Deductibility Of Capital Losses
In a nutshell, where the market value of such shares at the time of their issuance is lower than their book value, the difference may not be deducted from the taxable profits of the taxpayer at the time of the sale.
France
4 Jun 2015
12
Debt-Push-Down Challenged Under Abuse Of Law Theory
The French tax authorities challenged, under the abuse of law doctrine, the tax deduction of the interest payments made by FCo, on the grounds that the issuance of the ORAs was purely tax motivated.
France
3 Jun 2015
13
Treatment Of Foreign Nonprofit Organizations
As discussed in previous French Tax Updates, the treatment of French source dividends paid to foreign nonprofit organizations (NPOs) raises the issue of comparability of NPOs with French nonprofit organizations.
France
3 Jun 2015
14
Corporate Tax Treatment Of Loans Between A French Head Office And A Non-French Branch
A French bank, acting from its head office, had advanced loans to various branches located in China, Philippines, India, Singapore, and Thailand.
France
3 Jun 2015
15
French Tax Update - Recent Noteworthy French Tax Court Decisions
For VAT purposes, the French case law generally considers that the "transactions" between a head office and its PE are not within the scope of the tax (i.e., because they take place within the same legal entity).
France
7 May 2015
16
French Tax Update - Noteworthy Tax Courts Decisions And Draft Macron Law
The present French Tax Update will focus on (i) certain noteworthy tax courts decisions issued in the last months of 2014 and in the first months of 2015, and (ii) the so-called projet de loi Macron.
France
18 Mar 2015
17
New EUCJ Case On Dividend Withholding, Q2 Noteworthy Case Law, Amending Finance Law For 2014, And Parent-Subsidiary Directive Modification
In the years 2000 through 2008, an equity derivatives unit of the taxpayer was trading in Dutch equities derivatives.
France
9 Jul 2014
18
French Tax Update - Proposed Changes To The EU Parent–Subsidiary Directive, Q2 Noteworthy Publications, And FATCA And BEPS Updates
This update will look over changes to the EU Parent–Subsidiary Directive, recent advisory opinions issued by the Committee, recent case law, and other issues.
France
4 Jun 2014
19
German Tax Court Rules On Termination Of Fiscal Unity Under International Reorganization
An intra-group reorganization involving the transfer of shares in a German subsidiary does not constitute a good cause to terminate the fiscal unity.
Germany
12 May 2014
20
German Constitutional Court Issues Ruling On Retroactivity Of Tax Laws
The German Constitutional Court (Bundesverfassungsgericht) issued a decision in respect to a tax law that had retroactive effect when it was enacted.
Germany
12 May 2014
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