French Tax Update - Focus on Non-Cooperative Jurisdictions and Recent Tax Publications

The present French Tax Update will be two-fold. We will first take the opportunity of the Panama Papers leak to look over the French list of so-called non-cooperative jurisdictions and the corresponding tax rules applicable to payments and investments made in such jurisdictions. As usual, we will also comment on several significant decisions issued by French tax courts (including inter alia the application of transfer pricing principles to an exclusive distribution agreement, the compliance with the Constitution of the allowances for holding period under the personal income tax regime for capital gains and the exemption from such 3 percent tax for buybacks of shares), as well as recent publications made by the French tax authorities (in relation to transactions generally viewed as abusive by the tax audit services) and the European Union Commission (in relation to its VAT Action Plan).

Please contact Siamak Mostafavi if you are interested in this issue.

Jones Day publications should not be construed as legal advice on any specific facts or circumstances. The contents are intended for general information purposes only and may not be quoted or referred to in any other publication or proceeding without the prior written consent of the Firm, to be given or withheld at our discretion. To request reprint permission for any of our publications, please use our "Contact Us" form, which can be found on our website at www.jonesday.com. The mailing of this publication is not intended to create, and receipt of it does not constitute, an attorney-client relationship. The views set forth herein are the personal views of the authors and do not necessarily reflect those of the Firm.