French Tax Update - Back-To-School: Recent Case Law and Official Publications

The present early fall French Tax Update will first provide an overview of several significant decisions issued by French courts on tax issues, including: (i) the constitutional ruling on the 3 percent contribution on distributed income and its consequences for French tax groupings; (ii) the clash between a recent European Court of Justice decision with prior French case law on the application of VAT rules to transactions between a head office and its foreign branch; and (iii) the confirmation by the Conseil d'Etat that the foreign tax credits provided by a double tax treaty may not be reimbursed in the case where they could not be offset.

Please contact Emmanuel de La Rochethulon 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.