Copying and distributing are prohibited without permission of the publisher

France Archive

  • December 2014

    European Commission to seek information on tax rulings from all member states

    December 17, 2014

    The European Commission has expanded its state aid inquiry into tax rulings to cover all 28 EU member states.

  • Digital goods enter the 21st century of taxation

    December 16, 2014

    Richard Asquith, VP of Global Tax Compliance at Avalara, explains upcoming changes to European Union VAT rules and how they will affect digital service providers from January 1 2015. The changes are contained within article 58 2006/122/EC of the EU VAT Directive and all 28 member states are in the process of ratifying the changes through local VAT legislation.

  • Anti-abuse clause added to EU Parent-Subsidiary Directive

    December 16, 2014

    The Council of the European Union has approved an amendment to the EU Parent-Subsidiary Directive in a clampdown on aggressive corporate tax avoidance.

  • Netherlands court reinforces ECJ position on Dutch fiscal unity regime

    December 12, 2014

    Judgments in three cases by the Court of Appeals Amsterdam (CAA) yesterday have stated that the Netherlands’s restrictions on its fiscal unity rules go against European freedom of establishment principles.

  • OECD tax revenues approaching pre-crisis levels

    December 11, 2014

    Tax burdens in the OECD rose 0.4 percentage points in 2013 to an average of 34.1% of GDP, following rises of 0.3 percentage points in both 2012 and 2011.

  • North America leads global increase in MAP uptake

    December 05, 2014

    The US and Canada are at the forefront of a global increase in new mutual agreement procedures (MAPs) being initiated, OECD figures show.

  • November 2014

    EC’s Raponi speaks about future of EU VAT mini one-stop shop

    November 21, 2014

    Donato Raponi, head of the European Commission’s VAT Unit, has spoken about the potential for the scope of the EU’s VAT mini one-stop shop (MOSS), which will be rolled out from January 1 2015, to be expanded further.

  • Significance of Skandia VAT case hinges on interpretation - and translation - of key paragraph

    November 07, 2014

    The significance of the Skandia ruling for taxpayers across Europe depends on domestic VAT grouping rules, and interpretation of the ruling should be taken from the original Swedish verdict.

  • Luxembourg comfort letter tax deals could spell trouble for EC’s Juncker

    November 06, 2014

    The leaking of documents detailing tax arrangements Luxembourg has agreed with hundreds of corporate taxpayers is adding to pressure on Jean-Claude Juncker, president of the European Commission, after last month’s state aid investigation launches into deals signed by the Grand Duchy while Juncker was prime minister had already cast doubt on the appropriateness of his Commission appointment.

  • October 2014

    France asserts PE in commissionaire structures again

    October 30, 2014

    Eric Meier and Ariane Calloud, of Baker & McKenzie, analyse a recent case about potential permanent establishment of a French entity operating under a commissionaire arrangement with its Swiss principal.

  • Netherlands tops table of best VAT collectors as EU VAT gap grows to €177 billion

    October 29, 2014

    The Netherlands has again ranked at the top of the European Commission’s annual study into the VAT gap – the difference between expected VAT revenue and actual revenue collected – meaning its compliance and enforcement measures are the most efficient in the region, but the EU VAT gap grew to €177 billion.

  • Kokott takes aim at Marks and Spencer exception on EU group loss relief again

    October 24, 2014

    Juliane Kokott, an Advocate General of the European Court of Justice (ECJ), believes the Court’s decision on group loss relief in the Marks & Spencer case should be overturned.

  • Asquith joins Avalara as VP global tax

    October 21, 2014

    He will be responsible for for the company's efforts to help businesses manage compliance obligations as they enter new markets.

  • Monaco joins convention on tax assistance

    October 17, 2014

    Monaco has become the latest jurisdiction to sign the Multilateral Convention on Mutual Administrative Assistance in Tax Matters, the international instrument developed jointly by the OECD and the Council of Europe to fight international tax avoidance and evasion

  • EU launches new web portal to ease transition to new VAT rules

    October 15, 2014

    The European Commission has developed a new web portal and a ‘mini one stop shop’ to help businesses prepare for the changes in VAT collection rules.

  • Ryan hires Jean-Paul Ouaksel to lead its new Paris office

    October 06, 2014

    Ryan has recruited Jean-Paul Ouaksel as principal of the US firm’s newly-opened Paris office.

  • OECD unveils plan for 2014/2015 BEPS work

    October 02, 2014

    The OECD is getting straight back to work on base erosion and profit shifting (BEPS).

  • September 2014

    G20 tax agenda is not all about BEPS

    September 26, 2014

    The G20’s finance ministers have outlined their plans to minimise global tax avoidance and evasion, which are not only about completing the work of the BEPS Action Plan on time by the end of next year.

  • OECD addresses aggressive international tax strategies: What do the measures mean for your business?

    September 19, 2014

    This week, the Organisation for Economic Co-operation and Development (OECD) released its first recommendations for combating international tax avoidance. The announcements, which form part of the multilateral organisation’s Base Erosion and Profit Shifting (BEPS) initiative, mark a major change to the global tax and transfer pricing landscape and will have an impact on multinational enterprises worldwide.

  • GE’s Will Morris on BEPS release: Business still concerned about burdensome reporting requirements

    September 18, 2014

    Will Morris, chairman of the BIAC Tax and Fiscal Affairs Committee and global tax policy adviser for GE, weighs up the strengths and weaknesses of the OECD’s BEPS disclosure documents.

  • The BEPS project at halfway

    September 16, 2014

    In this exclusive article for International Tax Review, Pascal Saint-Amans and Raffaele Russo of the OECD explain how the first half of the BEPS Project's work starts the task of bringing coherence, substance and transparency to international tax rules around the world.

  • The tax market reacts to the BEPS 2014 deliverables: Do you agree?

    September 16, 2014

    The OECD today unveiled its 2014 deliverables at the halfway stage of the multilateral organisation’s ambitious base erosion and profit shifting project, commissioned by the G20, which represents the biggest ever review of international tax rules.

  • World's leading tax controversy advisers unveiled

    September 05, 2014

    The fourth edition of International Tax Review's Tax Controversy Leaders guide is out now. Find out who the top-rated disputes specialists are in your jurisdiction.

  • ONE adds to pressure on G20 to act against tax evasion and other illegal financial flows

    September 03, 2014

    The ONE campaign describes corruption involving developing countries as the $1 trillion scandal and says the G20 must implement measures such as automatic information exchange (AIE) and the transparent publication of the revenues governments receive if the organisation wants to end it.

  • Werner Schuster of Philip Morris: Why in-house is better than private practice

    September 02, 2014

    In an exclusive interview with International Tax Review, Werner Schuster, vice-president – head of tax at Philip Morris International (PMI), outlines the benefits of working in an in-house tax team, points out how technology is only as good as the data you input and explains why PMI does not outsource its tax functions.

  • August 2014

    World Tax Authority: Taking harmonisation to the next level

    August 29, 2014

    Recent attempts at tax harmonisation have struggled to take off. In Europe enhanced cooperation measures are being invoked because of the inability to find consensus. But what fate awaits the notion of a World Tax Authority (WTA)? Would it take tax harmonisation to the next level or, like the Europe-wide language of Esperanto, is this attempt at harmonisation doomed to fail? Matthew Gilleard analyses what has motivated discussion of such a concept and looks at the barriers to implementation.

  • Going the extra mile - when finance and IT suddenly awoke

    August 29, 2014

    In the July/August issue, Frank Schoeneborn, head of group operational transfer pricing in the finance and accounting division at Merck Group, took a retrapolative look at the country-by-country reporting standard five years into its implementation. In part two, he looks at how different functions within a multinational company are interacting with the tax team to manage reporting obligations.

  • Alternative dispute resolution: Alleviating burdens all round

    August 29, 2014

    The number of tax disputes is increasing rapidly around the world. The trend is encouraging governments to turn to alternative dispute resolution (ADR) in a bid to reduce backlogs in the courts. While ADR is well established in some jurisdictions, in others it is just getting going. Aaran Fronda looks at how ADR has become an increasingly viable solution for resolving tax disputes.

  • The IMF and international tax

    August 29, 2014

    David Spencer, of the Law Offices of David Spencer in New York, analyses the recent work of the International Monetary Fund (IMF) and assesses its growing influence in the area of international taxation.

  • Is it time to scrap the FTT?

    August 28, 2014

    With financial institutions struggling to deal with an abundance of new regulation, a new report urges the new EU Commission and Parliament to focus on growth, rather than implementing a badly designed tax that could spell disaster for the European economy.

  • Taxand appoints Alain Recoules as new global indirect tax leader

    August 26, 2014

  • Amazon struggles to resolve $1.5 billion dispute with IRS

    August 06, 2014

    The international e-commerce company, Amazon, has failed to resolve elements of its transfer pricing dispute with the Internal Revenue Service (IRS). The case revolves around the retailer’s use of a European subsidiary to reduce its tax bill which, if it loses, could cost the company billions.

  • APM Terminals global tax head: Divergent thinking is the way forward

    August 01, 2014

    In part two of International Tax Review’s exclusive interview, Steven Ouwerkerk, global head of tax & treasury at APM Terminals, based in the Netherlands, discusses the transition from adviser to in-house professional, analyses the challenges an in-house tax team faces, and stresses the importance of thinking divergently to find creative solutions.

  • July 2014

    APM Terminals global tax head: The importance of continuous dialogue with your CFO

    July 25, 2014

    In the first part of International Tax Review's exclusive interview, Steven Ouwerkerk, global head of tax & treasury at APM Terminals, based in The Hague, Netherlands, talks about the need for in-house tax teams to maintain consistent engagement with the boardroom and CFO, and reveals what it is that keeps him up at night.

  • OECD answers your questions about the global automatic exchange standard

    July 24, 2014

    EXCLUSIVE: On Monday July 21 the OECD released the full version of the Standard for Automatic Exchange of Financial Account Information in Tax Matters, which requires financial institutions to report detailed financial account information to their governments, which then exchange such information automatically with other jurisdictions on an annual basis. The Standard developed by OECD in response to a mandate by the G20 was first presented to and endorsed by the G20 Finance Ministers in February 2014.

  • Automatic exchange of information gets closer with OECD's publication of global standard

    July 21, 2014

    The OECD today unveiled the full version of the new global standard for automatic exchange of information between jurisdictions, which will be presented to the meeting of G20 finance ministers in Cairns, Australia on September 20 and 21.

  • Have your say on ITR's development

    July 14, 2014

    The new website went live in late May. Take the opportunity to influence how it develops by completing our survey.

  • Semeta extols EU efforts on tax compliance and promises more

    July 10, 2014

    Algirdas Semeta has said European taxpayers should see big improvements in compliance in the coming years.

  • Herve Israel joins DLA Piper

    July 07, 2014

  • What chief financial officers need from their tax directors

    July 02, 2014

    Jean-Louis Huchant, a former chief financial officer in France, writing here in a personal capacity, explains what information and support a CFO requires from a tax director to ensure that tax considerations are taken into account, though do not dominate, business decisions.

  • BEPS and the digital economy: Why is it so taxing to tax?

    July 01, 2014

    Devising appropriate rules for the taxation of the digital economy is one of the most awkward challenges governments have set for themselves in the BEPS project, especially when defining the digital economy is an issue in itself. Aaran Fronda looks at the possible outcomes of the discussion.

  • In search of harmony: Finding a consensus on hybrid mismatches

    July 01, 2014

    Mismatches create opportunities. This is true in any scenario, whether it is the opportunity for a fleet-footed and nimble winger to gain an advantage by exposing the bulky, flat-footed front-row rugby forward who has temporarily become his opposite man, or whether it is in the (equally ruck-filled) field of tax planning. Matthew Gilleard looks at where the OECD is drawing the line when it comes to activity that takes advantage of tax law mismatches in an intended or acceptable manner, and that which is not.

  • BEPS scepticism still rife despite OECD’s attempts at reassurance

    July 01, 2014

    The OECD’s base erosion and profit shifting (BEPS) project has been a bone of contention in the transfer pricing arena ever since its inception, with concerns from taxpayers piling up despite constant efforts at reassurance. Sophie Harding discusses taxpayers’ most burning concerns and explores whether the OECD’s BEPS proposals are actually feasible.

  • European Tax Awards 2014

    July 01, 2014

    The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21.

  • What chief financial officers need from their tax directors

    July 01, 2014

    Jean-Louis Huchant, a former chief financial officer in France, explains what information and support a CFO requires from a tax director to ensure that tax considerations are taken into account, though do not dominate, business decisions.

  • June 2014

    G8 has “broken promises” on tax transparency

    June 25, 2014

    Christian Aid, ActionAid, Global Witness and the Financial Transparency Coalition have accused G8 countries of failing to live up to the promises they made on tax and transparency a year ago at the Lough Erne summit in Northern Ireland.

  • Indirect Tax Leaders 2014 now available

    June 23, 2014

    The third edition of International Tax Review's Indirect Tax Leaders' Guide, is all about identifying the leading professionals in this field, which is only increasing in importance. Between its covers, you will find the names, and biographies in many cases, of the world's leading indirect tax practitioners, which were collected after an independent research process. It should give taxpayers confidence that if they decide to hire any of these individuals, they will be getting the best in the field.

  • Transfer Pricing Focus 2014 now available

    June 23, 2014

    BEPS has taken centre stage in global transfer pricing over the past year and recent debates have focused on country-by-country reporting, among other things. The issue of profit shifting has consequently been a strong theme in this year's transfer pricing supplement, but readers can also get the latest updates on supply chain management and insights into regulation changes from a jurisdictional perspective.

  • May 2014

    In it together: How the FTT could galvanise Europe

    May 27, 2014

    To say that the European financial transaction tax (FTT) has been controversial would be an understatement. From its inception in September 2011, the EU proposal has been met with vitriol from some in the financial sector, who argue that the tax will pilfer pensions and wreak havoc on the European economy, while others have championed it as the solution to the eurozone crisis, labelling it the ‘Robin Hood Tax’. It also has the added advantage of appeasing a politically disillusioned electorate by promising to land a decisive blow to bankers, who in the public’s view caused the mess in the first place. Aaran Fronda dissects this divisive tax.

  • Avoiding the snares of international tax structures

    May 27, 2014

    International business expansions can substantially increase the bottom line, but this outcome is largely dependent on establishing an efficient structure that helps to ensure financial success. Lee Sheehan, head of tax at Radius, looks at the importance of a clear strategy when setting up tax structures for specific business locations, and points out some of the landmines to avoid along the way.

  • Mammoth rise in tax audits worldwide

    May 23, 2014

    Tax audits have risen 73% worldwide, giving corporations around the world plenty to think about when it comes to having their tax affairs in order.

  • What foreign direct investors should look out for when using a limited liability partnership to come to India

    May 23, 2014

    The popularity of limited liability partnerships for investing in India means clarification on the tax and regulatory issues is required, believes Tirthesh Bagadia of Bagadiya & Jain

  • European Tax Awards' winners unveiled

    May 22, 2014

    The winners of the European Tax Awards 2014 were announced at a dinner in London on May 21.

  • World Tax 2016 and World Transfer Pricing 2016: Research opens in May 2015

    May 21, 2014

    The research will start for the 2016 editions of World Tax and World Transfer Pricing in May 2015. Please watch this website closely for further information.

  • Declaration commits OECD and other countries to automatic exchange of information

    May 07, 2014

    Taxpayers must get used to the Common Reporting Standard as the means for the introduction of automatic exchange of tax information around the world.

  • US updates FATCA list of intergovernmental agreements

    May 02, 2014

    The number of jurisdictions considered to have an intergovernmental agreement (IGA) in place with the US for the implementation of the Foreign Account Tax Compliance Act (FATCA) has passed 50.

  • Participants in OECD’s work on BEPS action plan emphasise importance of multilateralism

    May 01, 2014

    Politicians, officials and taxpayers spelled out the need for the outcomes of the BEPS project to work for companies and governments at the European Tax Policy Forum annual conference in London this week.

  • April 2014

    According to plan? The world of tax planning is changing, but not as fast as everyone would like

    April 30, 2014

    The world of tax planning is like one big global tug o’ war being played between multinational companies and their advisers, tax authorities, supranational bodies and non-governmental organisations. Everyone has an interest in changing the international tax system. But with everyone pulling in different directions, the pace of change is frustrating for most.

  • Managing TP risks in Nigeria: The importance of proactivity

    April 30, 2014

    Nigerian transfer pricing rules are still in their relative infancy, but taxpayers must take adequate steps to prepare now if they are to effectively identify risk areas and plan with both the company policy and the prospect of audit in mind. Victor Adegite of KPMG Nigeria provides an overview and looks at what lessons can be learnt from experiences around the world.

  • France latest to move ahead of OECD on BEPS with hybrid mismatch guidelines

    April 25, 2014

    French authorities have released draft guidelines for legislation enacted at the end of December targeting hybrid mismatch arrangements, an aspect of international tax practice the OECD is also seeking to tackle as part of its BEPS Action Plan.

  • Three new tax partners at Clifford Chance

    April 24, 2014

  • Jupiter Asset Management urges OECD to leave CIVs out of treaty abuse reform measures

    April 17, 2014

    The OECD has published stakeholder responses to its discussion draft on Action Point 6 of the BEPS Action Plan, which deals with treaty abuse. Funds and asset managers are calling for disparate treatment of collective investment vehicles (CIVs), while others are urging the OECD to reconsider its treaty preamble.

  • Investment funds could be in the money after European court ruling against Poland

    April 11, 2014

    A European Court of Justice decision in favour of a US investment fund could cost EU member states billions of euros in withholding tax reclaims.

  • Nominations announced for European Tax Awards 2014

    April 10, 2014

    Deloitte and EY lead the race for International Tax Review’s 10th annual European Tax Awards, which will be presented at a dinner in London on May 21.

  • Quenedey leaves Dentons for King & Wood Mallesons SJ Berwin

    April 07, 2014

  • Clarity behind US move to add 22 jurisdictions to FATCA list

    April 04, 2014

    It is not a global information reporting network yet, but the US Treasury and Internal Revenue Service’s announcement this week that increases the number of intergovernmental agreements for the Foreign Account Tax Compliance Act (FATCA) from 26 to 48 in one go brings that idea much closer.

  • March 2014

    Operational TP: When tax function meets finance function

    March 28, 2014

    Frank Schoeneborn, head of global operational transfer pricing in the finance and accounting division at Merck Group with headquarters in Germany, looks at the practical problems in the implementation of operational transfer prices, illustrating the new tax risks stemming from these problems and showing how holistic management can be the solution.

  • US signs FATCA intergovernmental agreements with Chile and Finland

    March 12, 2014

    Chile and Finland have become the 23rd and 24th jurisdictions to sign bilateral intergovernmental agreements (IGA) to implement the Foreign Account Tax Compliance Act (FATCA) as the US moves slowly towards signing more than 50 with jurisdictions around the world.

  • Aurélia de Viry launches King & Spalding's French tax practice

    March 06, 2014

  • Advocate General believes Dutch fiscal unity rules breach EU's freedom of establishment

    March 03, 2014

    The Netherlands and other EU member states could be forced into changing their tax legislation if the European Court of Justice (ECJ) confirms an Advocate General's view in cases relating to whether Dutch companies can freely establish fiscal unities with members of the same group.

  • February 2014

    Business Roundtable calls for tax reform pressure to be maintained following Camp’s discussion draft

    February 28, 2014

    The US tax reform discussion draft from Dave Camp, chairman of the House Ways and Means Committee, achieves two key goals for business, says John Engler, the leader of one of America’s most influential employers’ organisations: a corporate tax rate of 25% and a modern tax system.

  • Big fish: The world's leading transactional firms revealed

    February 26, 2014

    International Tax Review analyses the global M&A trends over the last year and highlights the leading firms in the field.

  • New regulations show US is listening to compliance concerns on FATCA

    February 26, 2014

    The US Treasury and Internal Revenue Service have responded to industry concerns in the final and temporary regulations for the Foreign Account and Tax Compliance Act (FATCA). However, the effective date of July 1 2014 was not changed.

  • FTT deal might be made in May says EU Commissioner Semeta

    February 25, 2014

    The European Commission is optimistic the financial transaction tax (FTT) could be ratified as early as May.

  • OECD standard makes progress towards automatic exchange of information

    February 13, 2014

    Global automatic exchange of financial account information got a step closer today after the OECD published its Common Reporting Standard.

  • OECD seeks increased tax transparency from multinationals

    February 06, 2014

    The OECD has released a discussion draft outlining its proposals on information that multinationals may be required to disclose to tax authorities about their global operations.

  • January 2014

    France prepares for battle with EU over digital VAT

    January 30, 2014

    The French government wants to cut VAT on digital content. The European Commission wants France to raise its already reduced rate for e-books. Let battle commence.

  • The dark side of transparency

    January 28, 2014

    Tax transparency is lauded as an unequivocal good. But is it really this clear-cut? Matthew Gilleard explores the negatives as he ventures into the dark side of transparency.

  • Special features - February 2014

    January 28, 2014

    Read this month's special features on Canada and Tax compliance.

  • Getting value from advisers: An in-house perspective

    January 28, 2014

    Patrick Connolly is an experienced senior in-house tax adviser who has spent the past 10 years in in-house regional tax roles covering Europe, the Middle East, Africa and the Asia/Pacific regions as well as head office tax responsibilities. He shares his views on getting the most value from the client/adviser relationship. Paul Dunne, national managing tax partner for KPMG New Zealand and the tax lead on a number of multinational clients, provides his response and comments.

  • Tax, development and the new Millennium Development Goals

    January 28, 2014

    Seth Terkper, Ghana’s minister of finance, and Hafiz Choudhury, senior adviser, International Tax and Investment Centre, discuss the challenges for developing countries in creating tax systems that raise enough revenue to fund development and also encourage investment.

  • Hollande to cut French business taxes – but there’s a catch

    January 23, 2014

    President Francois Hollande has proposed a €30 billion ($40 billion) easing of the French business tax burden, but only if companies show a commitment to invest and hire.

  • Semeta proposes phased implementation of FTT

    January 22, 2014

    Algirdas Semeta, European Commissioner for Taxation and Customs Union, Audit and Anti-Fraud, has urged member states not to water down proposals for a financial transactions tax (FTT), arguing that present delays may be instead overcome by a phased implementation of the tax.

  • European Tax Awards 2014: submissions period now open

    January 20, 2014

    Companies and firms can now enter for the European Tax Awards 2014. Entry information is available in hyperlinks throughout this story.

  • Study confirms EU businesses’ claim that double taxation remains a key problem

    January 16, 2014

    A report from BUSINESSEUROPE reinforces the business community’s claims that double taxation outside of the area of transfer pricing remains a significant problem. At the October meeting of the European Commission’s Platform for Tax Good Governance, EU member states had claimed the issue was no longer relevant.

  • National Taxpayer Advocate points out flaws in FATCA implementation

    January 15, 2014

    The US National Taxpayer Advocate (NTA) has raised serious doubts about the creation of an international financial data regime as the goal of the Foreign Account Tax Compliance Act (FATCA).

  • France reworks millionaire tax to hit companies

    January 09, 2014

    French President Francois Hollande is to hit companies with a new charge on annual salaries of more than €1 million ($1.4 million).

  • Eight jurisdictions raise VAT in New Year

    January 08, 2014

    A number of large VAT rises rang in the New Year, but there are signs the rate of VAT rises is slowing in the more developed economies.

  • Final FFI agreement offers transition for due diligence

    January 08, 2014

    A change in the final version of a document critical to compliance with the Foreign Account Tax Compliance Act (FATCA) will allow financial firms to choose which form of due diligence procedures to follow.

  • France ups the pressure on non-cooperative states over exchange of information

    January 08, 2014

    The French tax authorities are likely to step up their scrutiny of so-called non-cooperative states and territories (NCST) in the future. International groups and private-equity funds should examine their structures to see if any measures related to this year’s list of such jurisdictions will affect them.

  • Italy imposes Google tax on web advertising

    January 08, 2014

    Italy’s parliament has passed the Google tax which will require companies to buy internet advertisements from locally-registered companies and not from companies based in tax havens including Bermuda and Ireland. But the proposal may violate EU laws on non-discrimination regarding commercial activity.

International Correspondents