Copying and distributing are prohibited without permission of the publisher

France Archive

  • December 2010

    Dividend taxation presents tricky issues for Europe

    December 28, 2010

    Philippe Freund analyses some of the key dividend tax issues that have been raised in European cases recently, such as exemption versus imputation and the use of exchange of information provisions

  • IP/IT taxation regimes modified

    December 01, 2010

  • November 2010

    Treaties of the week - November 22 2010

    November 22, 2010

  • The 21 biggest influences in tax today

    November 01, 2010

    To mark the 21st birthday of International Tax Review in November 2010, the editorial staff of the magazine decided to choose the 21 most influential people or organisations in tax today.

  • Twenty-one years in tax

    November 01, 2010

    As International Tax Review celebrates its 21st birthday in November 2010, Erin Kelechava takes the opportunity to look back at a selection of the notable events in tax since 1989.

  • Income tax treaty between Brazil and Venezuela

    November 01, 2010

  • Welcome clarification of the tax consequences of EU companies moving to France

    November 01, 2010

  • October 2010

    Jeffrey Owens to leave OECD

    October 11, 2010

    The OECD has advertised for a new director of its Centre for Tax Policy and Administration (CTPA) after the announcement that Jeffrey Owens is to retire from the post in January 2012.

  • Tobin tax divides Ecofin

    October 01, 2010

  • Middle East tax structuring and opportunities revealed

    October 01, 2010

    Alex Cole, Sean Finn & Daniel Friel of Latham & Watkins highlight some of the important differences between various Gulf states, focusing on the GCC, as well as showing how the tax issues facing investors are changing as the region's economic focus expands.

  • International social security – not my department

    October 01, 2010

    Francis Farrell and Charlie Ross of PricewaterhouseCoopers in Ireland outline why international social security is no longer a subject that tax directors should be avoiding.

  • September 2010

    Allen & Overy strengthens Paris tax practice

    September 26, 2010

  • Stephenson Harwood adds to Paris office

    September 03, 2010

  • Rising VAT rates here to stay

    September 01, 2010

    Several countries have announced or implemented VAT rises in the last few months. Salman Shaheen looks at the growing trend towards higher VAT around the world and why the global recession means it looks set to continue.

  • VAT travel service margin scheme concerns all taxpayers

    September 01, 2010

    The value added tax travel service margin scheme involves complex issues that concern businesses of all types, Stephen Dale of Landwell & Associés investigates the progress being made and how Europe might better develop the legal framework in this area.

  • Portugal adds to treaty network and information exchange agreements

    September 01, 2010

  • Social media for tax evaders

    September 01, 2010

    A monthly commentary on the notable facts, figures and goings-on in the tax world. Suitable items should be sent to

  • Argentina: Transfer pricing rules in need of change

    September 01, 2010

    Augusto Martín Camarero and Armando Cabrera describe the way Argentine transfer pricing rules still fall behind more developed tax codes. The lack of advance pricing agreements and quasi acceptance of secret comparables cause problems.

  • Brazil: Caution advised to avoid disaster

    September 01, 2010

    Simone Dias Musa, Clarissa Machado and Camilla Lagrasta explain how not following the OECD guidelines makes the Brazilian rules difficult to follow. With fixed margins regardless of industry and new thin capitalization rules, taxpayers need to be aware of the complex legislation.

  • Chile: Unclear if OECD principles apply to local rules

    September 01, 2010

    In Chile, the rules technically follow the OECD guidelines, but Miguel Zamora and Ana Paula Güitrón say it is not clear whether this is true. Advisers still struggle to know which transfer pricing methods are allowed.

  • Mexico: Moving forward along a different path

    September 01, 2010

    In Mexico, the transfer pricing rules have been in force since 1997, a relatively long time in Latin America. Moisés Curiel, Carlos Linares and Emilio Angeles talk taxpayers through staying on the right side of the notoriously strict

  • Peru: Transfer pricing rules are developing rapidly

    September 01, 2010

    Since the arm's-length principle was introduced in Peru in 2001, there have been multiple updates and extensions to the rules on transfer pricing. Claudia González-Béndiksen and Paola Gutiérrez list the important points taxpayers must be aware of, such as maintaining stringent documentation as well as filing an annual sworn informative return.

  • Venezuela: Taxpayers are at risk of severe penalties

    September 01, 2010

    Ronald Evans and Gustavo Sánchez discuss Venezuela's complex rules and explain that taxpayers must strive to comply with the legislation or face heavy penalties.

  • July 2010

    European heavyweights see common tax base as key to single market

    July 01, 2010

    The report by Mario Monti into how to complete the EU single market lends some support to the plans of Algirdas Semeta, European commissioner for tax, for a common corporate tax base. Salman Shaheen spoke to both men and other observers about the likelihood of the concept becoming reality

  • European awards winners take their prizes

    July 01, 2010

    The Alliance of Gleiss Lutz, Herbert Smith and Stibbe won the European Tax Firm of the Year for the first time at International Tax Review's European Tax Awards in London.

  • France consider new partnership legislation

    July 01, 2010

  • June 2010

    Taxpayers and governments clash over tax planning

    June 07, 2010

    The rise in aggressive tax planning and equally aggressive responses from governments the world over was top of the agenda at a conference in Copenhagen last week.

  • Why tax has a role in curbing effects of climate change

    June 01, 2010

    Environmental taxes are already playing a role in attempts to restrict damage caused by climate change. Now, as Salman Shaheen reports, the debate has shifted to arguments about what kinds of taxes are most suitable.

  • Zimmer wins French decision on permanent establishment

    June 01, 2010

    Taxpayers will be heartened by the decision of the French Supreme Tax Court in the Zimmer case on the existence of a permanent establishment. Renaud Jouffroy and Marie-Laure Hublot of Landwell et Associes examine the verdict, pointing out that it left some questions unanswered

  • Major reform of real estate VAT regime

    June 01, 2010

  • May 2010

    Plan your next move

    May 01, 2010

    Revenue authorities around the world have become an important tool for governments as they strive to raise income to boost their battered economies after the economic downturn of the last two years. And officials have put pressure on taxpayers to be transparent in their tax planning. The advisers who can ensure this level of service are to the fore in International Tax Review's third annual poll to find the world's leading planning practices

  • Rules refined to ensure Shari'ah compliance

    May 01, 2010

    As the economic turmoil recedes, the demand for Islamic financing is increasing again. It has led some key jurisdictions to reexamine their tax rules to ensure that such transactions are possible, explains Kevin Conway, John Taylor and Markus Krismanek of King & Spalding

  • New thinking on French group relief

    May 01, 2010

    French groups have more flexibility to decide how to divide the tax burden among its members after two Supreme Court decisions. However, the rulings could also change how M&A take place when it involves entities that have suffered losses, explain Renaud Jouffroy and Jean Sayag of Landwell et Associés

  • Panama makes progress on tax information requirements

    May 01, 2010

    Panama is working hard to dispel the perception of it as a tax haven. Catherine Snowdon talks to Alberto Vallarino, the country's minister of economy and finance, Frank De Lima, its vice minister of economy and Luis Eduardo Ocando, an international tax partner at Ernst & Young and adviser to the government on the strategy and negotiation of tax treaties.

  • April 2010

    Bipartisan tax reform fails to win consensus

    April 01, 2010

  • A time for tax transparency and clarity

    April 01, 2010

    Enhanced tax information exchange and greater offshore compliance was the biggest outcome of the G20 summit of world leaders last April in London. The subsequent 12 months saw increased tax cooperation between governments and hundreds of international information exchange agreements signed. Jack Grocott discovers what all this means for multinational companies.

  • Editorial

    April 01, 2010

    Getting off the blocks

  • France: French companies offered benefits of lower tax costs

    April 01, 2010

    Tax reforms have given companies in France have got plenty of incentives to make and structure acquisitions to their advantage, explains Xavier Etienne of Landwell et Associés

  • March 2010

    France abandons carbon tax plan

    March 23, 2010

    François Fillon, the French prime minister, has announced that the government has abandoned the proposed carbon tax which was due to come into force on July 1.

  • France awaits court verdict on possible VAT breach

    March 18, 2010

    Advocate General Nilo Jääskinen of the European Court of Justice (ECJ) has issued his opinion in European Commission v France. In his view, France is in breach of articles 96 and 98 of the EU VAT directive for allowing a reduced rate for services provided by lawyers. These services are for legal aid which France argues is in line with article 98 that allows for a reduced rate for works of social welfare.

  • Global tax transactional survey

    March 01, 2010

    Throughout the world, tax transactional advisers have adapted their advice to best support their clients during the economic downturn. Jack Grocott, Catherine Snowdon and David Stevenson speak to advisers and taxpayers in Asia, Europe and North and Latin America.

  • February 2010

    Countries face sanctions over information exchange

    February 18, 2010

    When they meet in Seoul in South Korea this month, finance ministers of the G20 nations are set to confirm that they will impose economic sanctions on developing nations that have failed to comply with the OECD's initiative on information sharing agreements.

  • OECD package seeks to help portfolio investors

    February 16, 2010

    The OECD has released for public consultation an implementation package that aims to make it easier for portfolio investors to claim treaty benefits.

  • France plan amended carbon tax

    February 15, 2010

    France's plan for a carbon tax was dealt a blow last month when the constitutional court ruled it unconstitutional as it contained too many exemptions and breached the equality principle.

  • Controversial tax goes to boost business climate

    February 01, 2010

    The French government has abolished the unpopular taxe professionnelle. David Stevenson finds out why it has done so and the prospects for the tax's replacement.

  • UK edges towards foreign profits reform

    February 01, 2010

    Diane Hay, formerly of the UK tax authorities, worked on the key provisions of what became the UK's new rules on the taxation of overseas income. In an extract from a new book she describes the final stage of the project

  • Driving the UN agenda on tax

    February 01, 2010

    Tax work at the UN can seem shrouded in mystery. Catherine Snowdon speaks to Michael Lennard about his career and the challenges of being the only tax technical specialist employed by the organisation.

  • France's carbon tax ruled unconstitutional

    February 01, 2010

  • Bredin Prat gains a partner

    February 01, 2010

  • HMRC feels unwell

    February 01, 2010

    A monthly commentary on the notable facts, figures and goings-on in the tax world, so called to give you a gentle exit from International Tax Review each month

  • January 2010

    France strengthens anti-avoidance and CFC rules

    January 25, 2010

    The French Finance Act 2010 strengthens the country's controlled foreign company (CFC) rules and includes new anti-avoidance rules that restrict tax benefits for income derived from a non-cooperative tax jurisdiction.

  • ICC wary of trends in international taxation

    January 21, 2010

    The International Chamber of Commerce (ICC) has criticised jurisdictions that are attempting to tax international transactions that do not take place within their borders.

  • France reforms business tax

    January 19, 2010

    France has abolished a controversial tax on assets that was criticised for hindering investment.

  • France wants to tax internet advertising

    January 12, 2010

    French president Nicolas Sarkozy has announced his government's intention to introduce a tax that will affect some of the biggest internet companies by taxing internet advertising.

  • France's carbon tax ruled unconstitutional

    January 05, 2010

    The French constitutional council has ruled that the proposed carbon tax on greenhouse gas emissions by households and business violates the equality principle because most industrial emissions were exempt.

International Correspondents