French Tax Update - Focus on the Anti-Avoidance Provision Targeting Hybrid Debt Instruments

French Tax Update is a periodic publication that examines the French hot topics in the field of tax.

In this month's issue:

Focus on the Anti-Avoidance Provision Targeting Hybrid Debt Instruments

• 25% Test 
• Look-Through Rule 
• Overlap with CFC legislation 
• Hybrid entities 
• Coordination with foreign anti-hybrid provisions

Other Official Publications:

• Update of the French financial transactions tax (FFTT) guidelines
• Administrative supreme court aligns accounting and tax treatment of provisions
• New double tax treaty between China and France 
• Forms to be used by trustees subject to disclosure obligations 
• Non-cooperative jurisdictions list update