French Tax Update - Debt Pushdown, Intragroup Fees, and Other Noteworthy Publications

The present French Tax Update provides an overview of several significant publications, including decisions issued by French tax courts over the past months relating to: (i) a debt pushdown challenged under the abuse of law theory, (ii) a transfer pricing reassessment of a real estate investment group, (iii) the rejection of a priority preliminary ruling request on the compliance with the French constitution (question prioritaire de constitutionnalité) of the French withholding tax applicable to dividend distributions paid to loss-making foreign shareholders, (iv) the general principles applicable to the valuation of unlisted shares, and (iv) the scope of the now-defunct exceptional contribution to French corporate income tax.

Please contact Emmanuel de La Rochethulon if you are interested in this issue.

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