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.