James Hardie loses appeal against Australian tax authorities Panellists to share dispute resolution experiences German Supreme Court reverses squeeze-out compensation position Vodafone ruling date announced WTO rules EU in breach of international rules Tax disputes leaders vie for Americas Awards Cover Story Features Comment News People and Firms Tax relief Argentina Brazil Canada Chile Finland France Germany India Ireland Italy Japan Mexico Poland Portugal South Africa Thailand Ukraine US Inbound US Outbound Foreign Account Tax Compliance Act: A critical analysis Bearer bonds The Netherlands Budget and the patent box Asia 2009 Europe 2009 Americas 2009		International Briefings - France September 2010 Court declares stock options gains are taxable in cross-border situations July 2010 France consider new partnership legislation June 2010 Major reform of real estate VAT regime December 2009 New rules on transfer pricing documentation and on tax avoidance November 2009 France plans reform to business tax September 2009 France hopes to introduce carbon tax soon May 2009 Local business tax to be replaced by energy tax framework April 2009 Withholding tax on dividends received by EU pension funds in breach of EC law March 2009 New protocols with the US and Switzerland bring significant changes February 2009 New bill introduces endowment funds with tax breaks to foster philanthropy December 2008 New legislation on transfer pricing postponed again November 2008 Anti-abuse provision declared not compatible with EU law October 2008 A more attractive tax regime for impatriates September 2008 VAT cuts, tax fraud and CCCTB are high on the agenda of the French EU Presidency July 2008 Tax treatment more favourable for foreign real estate investors June 2008 Some EU companies may benefit from partial refund of capital gains tax May 2008 French Tax Administration conduct not compatible with the European Convention of Human Rights April 2008 Withholding tax due by foreign pension funds in breach of non-discrimination principle March 2008 A win for the French banking and financial lobbies over invoices for exempt transactions February 2008 France enhances its R&D tax credit system March 2006 Court provides opportunity to obtain VAT refund on French motorway tolls November 2004 Draft Finance Bill proposes new rules on company transfers October 2004 Cases clarify inter-company aid September 2004 The Hallminster case and the UK treaty July 2004 New way of claiming reduced withholding tax benefit June 2004 When French companies set up a foreign holding and abuse of law May 2004 When a foreign parent charges central cost deductions to a French subsidiary April 2004 New withholding tax exemption case March 2004 Freedom of establishment trumps thin-capitalization rules February 2004 New incentives for expatriates December 2003 New Bill removes time limits for carrying forward losses November 2003 Why tax authorities cannot assess management decisions October 2003 Court refines the permanent establishment concept September 2003 Changes to the remuneration of inter-company services July 2003 New ruling on deemed distributed income June 2003 Fresh challenges to exit tax May 2003 Elimination of double taxation April 2003 International partnerships and branch tax March 2003 Recharacterizing the transfer of receivables February 2003 Courts tighten permanent establishment law December 2002 SA Maximo decision approves holding structures November 2002 Detailing the changes to transferring losses October 2002 Alienation of real estate and royalty payments under France-Canada treaty July 2002 Court denies use of dividend tax credits in abusive corporate income tax transactions June 2002 Non-resident real estate tax changes May 2002 Athinaiki and the French précompte April 2002 French tax authorities issue guidelines on avoir fiscal rate for tax credits to non-residents March 2002 ECJ jurisdiction over Danish case may affect French merger regime February 2002 Taxation of interest arrears court decision December 2001 New rules for mergers and assimilated operations in the Draft Finance Bill for 2002 November 2001 Parent-subisidiary regime guidance issued and stock option regime adopted at last October 2001 Tax treatment of the losses resulting from the absorption of a subsidiary September 2001 Court decision and France-Germany tax treaty July 2001 France-Poland treaty prevents French levy of branch withholding tax June 2001 Fixed asset value and court decision on the notion of dividends April 2001 French Court decision on permanent establishment under France-Switzerland tax treaty March 2001 Important decision regarding application of CFC rules February 2001 France December 2000 Banking and amortization November 2000 French draft finance bill for 2001 October 2000 New administrative guidelines September 2000 French tax authorities issue new guidelines on tax-free demergers July 2000 Branch tax ruling and the treaty with Switzerland June 2000 Recent court decisions and new stock options rules April 2000 New court decision on partnership issues March 2000 Recent court decision on partnership issue February 2000 Finance bills adopted at the end of December December 1998 New case law eases the use of tax losses June 1998 TRANSFER PRICING TREND May 1998 EXTENDED POWERS OF CONTROL OVER TRANSFER PRICING: THE AWAITED COMMENTARY April 1998 SHAM TRANSACTIONS REASSESSED March 1998 ELIMINATION OF FRENCH BRANCH TAX FOR EU COMPANIES February 1998 Changes to tax on passive income and individual taxation

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