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

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
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