Copying and distributing are prohibited without permission of the publisher

France Archive

  • December 2015

    The Cunningham column: China gets ready to lead tax world in 2016

    December 15, 2015

    China will be at the forefront of BEPS implementation in 2016, as president of the G20. Ralph Cunningham says it is a big opportunity for a non-OECD member to shape the international tax system.

  • The Brockman brief: BEPS implementation: A holiday wish

    December 15, 2015

    Drafters of the new base erosion and profit shifting (BEPS) actions and precision watchmakers share a common wish; that their immeasurable efforts devoted to refining and juxtaposing complex parts result in an instrument that is respected and trusted around the world.

  • BEPS Special

    December 15, 2015

    Matthew Gilleard introduces this exclusive, comprehensive insight into the work of the OECD in the area of countering tax base erosion and profit shifting (BEPS). Within these covers you will find out about the key messages delivered under each of the OECD’s 15 Actions, direct from the individuals responsible for putting each aspect of the project together.

  • Intercompany charges below EBIT: A double-edged sword

    December 15, 2015

    Luis Abrantes, tax director and head of transfer pricing at Carlsberg Group, draws on practical experiences to unpick the intricacies of intercompany charges.

  • 2016 Look-Ahead: BEPS implementation to dominate international tax landscape

    December 15, 2015

    With the final deadlines for the OECD’s BEPS Project falling at the end of this year, 2016 was always going to be a year dominated by questions about implementation. While BEPS-related activity is not the only issue on the horizon, that alone will ensure multinationals are kept busy over the next 12 months. Joe Stanley-Smith and Matthew Gilleard look through the peephole to analyse taxpayer hopes, fears and expectations for the year ahead.

  • European Tax Awards 2016: Submission period now open

    December 10, 2015

    Companies and firms can now enter for the European Tax Awards 2016.

  • November 2015

    EC grills 11 LuxLeaks multinationals on tax; extends mandate for tax rulings investigation

    November 26, 2015

    Following the questioning of Anheuser-Busch InBev, Coca-Cola, Disney, IKEA, Amazon, Google, HSBC, Barclays, Facebook, Philip Morris International and McDonald’s, the mandate of the European Commission’s (EC’s) TAXE Committee has been extended.

  • October 2015

    Mind your own business: The importance of knowing what we really do

    October 29, 2015

    Steven Ouwerkerk, global head of tax at APM Terminals, argues that to deal with the corporate challenges of operating in an increasingly borderless world, multinationals must learn to operate in a department-less manner, sharing experiences across functions and understanding issues from a variety of perspectives. He also brings a new meaning to the phrase ‘mind your own business’.

  • The Brockman brief: Tax transparency: Is it a one-way street?

    October 29, 2015

    The envisaged ideals of ‘tax transparency’ are being proposed, and legislated, by tax administrations worldwide. This month’s Brockman brief focuses on the fact that mutual and reciprocal tax transparency with multinational entities (MNEs) remains somewhat elusive. It is now time to briefly assess some of these initiatives to fairly gauge the mutuality of such initiatives.

  • BEPS implementation: The role of a multilateral instrument

    October 27, 2015

    Jeffrey Owens, director of the Global Tax Policy Centre at the Vienna University of Economics and Business (WU) Institute for Austrian and International Tax Law (IAITL) and former OECD tax chief, and Nathalie Bravo, research associate at the IAITL, explore the role of a multilateral tax instrument in implementing BEPS Project measures, and analyse the treaty issues and technical challenges to be overcome.

  • European Court of Justice exempts bitcoin trading from VAT

    October 22, 2015

    The European Court of Justice (ECJ) has ruled that bitcoin trading services should be exempted from VAT entirely, effectively classifying the cryptocurrency as money.

  • Eight out of ten businesses still using spreadsheets for VAT compliance

    October 14, 2015

    More than 80% of businesses are still using spreadsheets to manage their VAT compliance in at least one jurisdiction in which they operate, despite tax authorities around the world investing in better tools.

  • Lenaerts to serve three-year term as ECJ President

    October 12, 2015

    Koen Lenaerts has been elected by his peers to a three-year presidential term at the helm of the European Court of Justice (ECJ). Antonio Tizzano will serve as vice-president.

  • September 2015

    The Brockman brief: Performance review: The OECD’s reputation

    September 29, 2015

    The curtain is drawing to a close on the final OECD BEPS recommendations, while the OECD actors and supporting staff anxiously await reaction from the audience. This month’s Brockman brief runs the rule over the OECD’s BEPS work to date and looks ahead to see how developments are likely to impact the organisation’s reputation as the ‘go-to’ body for international tax matters.

  • DSM to be enhanced during destination principle expansion

    September 29, 2015

    Key figures at the European Commission have outlined the importance of the digital single market (DSM) as they prepare to extend the destination principle and mini one-stop shop (MOSS). Joe Stanley-Smith investigates.

  • Moscovici calls for action as EU VAT gap rises again

    September 29, 2015

    Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, has urged EU member states to tighten up VAT collection after new figures showed €168 billion was lost in 2013. Joe Stanley-Smith reports.

  • Moscovici calls for action as EU VAT gap rises again

    September 16, 2015

    Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, has urged EU member states to tighten up VAT collection after new figures showed €168 billion was lost in 2013.

  • Broad VAT debate at Fiscalis conference

    September 09, 2015

    A three-day VAT conference attended by business representatives, industry bodies and all 28 EU member states’ tax authorities concluded on Wednesday 9 September. The discussions have laid the groundwork for future legislative proposals.

  • EU tax officials descend on Dublin for key VAT conference

    September 07, 2015

    Taxpayers’ eyes will be on Dublin, Ireland today when a key conference on the future of VAT in the EU kicks off. Key discussions around the destination principle and the mini one-stop shop (MOSS) will take place.

  • ECJ rules against French dividend legislation in Steria case

    September 04, 2015

    The European Court of Justice (ECJ) has ruled in favour of multinational IT company Steria in its dispute with France. It could lead to major changes regarding fiscal integration and refunds for some companies.

  • August 2015

    Issues the economist forgets? TP policy – a banking perspective

    August 21, 2015

    After spending 15 years in-house, Ben Henton last month joined BDO as a transfer pricing director. He returns to the UK from Asia after four years working at HSBC and DBS Bank in Hong Kong and Singapore. Here, he addresses operational risk challenges in transfer pricing (TP) from an in-house perspective, going beyond technical TP legislation and guidelines.

  • A tax system for sustainable growth

    August 21, 2015

    In this exclusive op-ed piece for International Tax Review, Chris Lenon, former head of tax for Rio Tinto and an expert witness to the Independent Commission for the Reform of International Corporate Taxation (ICRICT), argues that a focus on incentives and ultra low or no tax jurisdictions should be policy makers’ priority, rather than ideas included in the commission’s report, such as allocation.

  • July 2015

    FTT could push financial institutions abroad

    July 30, 2015

    Financial institutions including French bank BNP Paribas could leave the 11 countries involved in the proposed European financial transaction tax (FTT) to relocate their headquarters in financial centres such as London and New York.

  • Luxembourg extends first FATCA deadline

    July 30, 2015

    Luxembourg has extended tomorrow’s deadline for financial institutions to submit their first report under the US Foreign Account Tax Compliance Act (FATCA). Mauritius has also announced a similar extension.

  • EC tells France to recover €1.37 billion from EDF

    July 28, 2015

    The European Commission (EC) has ordered France to recover €1.37 billion ($1.50 billion) from Électricité de France (EDF), the energy company, for tax breaks given to the company in 1997.

  • Kokott recommends Europe exempts Bitcoin from VAT in ECJ Opinion

    July 21, 2015

    Cryptocurrencies such as Bitcoin should be exempt from VAT, according to Advocate General Juliane Kokott’s Opinion in a Swedish European Court of Justice (ECJ) case.

  • The Brockman brief: Illusory transparency: A symptom of BEPS complexity

    July 10, 2015

    The inception of the OECD’s base erosion and profit shifting (BEPS) action plans was accompanied by new demands for fiscal transparency, ignoring omnipresent thorns of complexity.

  • Vicious and virtuous circles: Planning for change with Schroders’ group tax head

    July 10, 2015

    Joe Stanley-Smith talks to Sue Cooper, group head of tax at global asset management company Schroders, about inter-departmental cooperation, planning for change and the difference between vicious and virtuous circles.

  • European Tax Awards 2015

    July 10, 2015

    The Grosvenor House Hotel on London’s Park Lane was the new venue for the 11th annual European Tax Awards dinner on May 21.

  • June 2015

    Baker & McKenzie takes new principal tax adviser from EY

    June 25, 2015

    Kate Alexander has joined Baker & McKenzie in London as a principal tax adviser, a partner-equivalent position.

  • Belgium referred to ECJ in overseas property tax dispute

    June 25, 2015

    The European Commission (EC) has referred Belgium to the European Court of Justice (ECJ) over its tax treatment of Belgian taxpayers holding property abroad.

  • FTT announcement likely next month

    June 24, 2015

    The proposed European financial transaction tax (FTT) could be back on track after the 11 participating nations met on Thursday (June 18) to discuss the plan.

  • Saint-Amans and Bhatia hit out at EU non-cooperative list

    June 24, 2015

    The OECD, and the Global Forum on Tax Transparency and Exchange of Information, which it organises, have moved to assert their preeminence as the international bodies that discuss and decide on transparency and exchange of information standards.

  • French tax treatment of foreign dividends and interplay with fundamental EU freedoms

    June 23, 2015

    French corporate tax legislation stipulates that distributions of profits from a subsidiary to a French parent company are not, in principle, taxed at the parent. Excluded from this, however, is a 5% proportion, which represents the charges incurred by the French parent company in connection with its holding in the subsidiary. These charges are not to be deductible because they serve the realisation of non-taxable income by the French parent company, namely the distribution of profits from its subsidiaries.

  • EU's tax transparency consultation keeps focus on public disclosure

    June 18, 2015

    The European Commission said the aim of the public consultation into tax transparency, which it launched on June 17, is to learn whether the public wants corporations to disclose more about the taxes they pay and if this "could help to tackle tax avoidance and aggressive tax practices in the EU".

  • Common tax base at fore of European Commission's plans for corporate taxation

    June 17, 2015

    The European Commission launched its much-anticipated Action Plan on Corporate Taxation today, basing it on the idea of the Common Consolidated Corporate Tax Base as a 'holistic solution to corporate tax reform' and the principles of ensuring effective taxation and increasing transparency.

  • HMRC’s light touch approach for EU VAT extended indefinitely

    June 17, 2015

    The UK revenue authority, HMRC, has confirmed that it will extend its ‘light touch’ approach for the 2015 EU VAT regulations “indefinitely”. The policy had been due to expire at the end of June 2015.

  • May 2015

    The Brockman brief: UK diverted profits tax: The extrapolation effect

    May 27, 2015

    The UK's diverted profits tax (DPT) was developed, and enacted, quickly in the weeks leading to the general election. The legislation was a two-pronged attack: on transactions having insufficient economic substance and the avoidance of permanent establishment (PE). The legislation went into effect April 1 2015 and there have been hints that other countries are looking at similar moves; but exactly what tax doctrines will other countries adopt to achieve similar objectives?

  • BEPS: Improving data, economic analysis and measurement

    May 27, 2015

    It is stating the obvious to say that current international efforts to tackle base erosion and profit shifting (BEPS) have attracted a great deal of global attention. Since the OECD and G20 countries, working together on an equal footing, adopted a 15-point action plan to address BEPS in September 2013, the focus on this issue has steadily grown. David Bradbury, head of the tax policy and statistics division at the OECD Centre for Tax Policy and Administration, and the man overseeing this aspect of the project, provides exclusive insight into an action point that has not always received as much attention as other items in the Action Plan.

  • European Tax Awards 2015 - the winners

    May 22, 2015

    The European Tax Awards 2015 were presented on May 21 at a dinner at the Grosvenor House Hotel in London.

  • Ansip to propose EU-wide VAT threshold “as soon as possible”

    May 19, 2015

    Andrus Ansip, European Commission vice president for the digital single market, has promised to launch a proposal for an EU-wide VAT threshold on business-to-consumer (B2C) e-services “as soon as possible”.

  • JPMorgan under investigation for tax evasion in France

    May 14, 2015

    France has launched a formal investigation into American bank JPMorgan over allegations that some of its senior managers helped French investment company Wendel to evade tax.

  • EC's digital single market strategy aims to reform VAT for B2C online retailers by 2017

    May 13, 2015

    The European Commission‘s ambitious plans to improve the digital single market include changes to the VAT treatment of the cross-border supply of goods and services.

  • April 2015

    Election comes at a bad time for UK businesses as France looks to block EU VAT threshold

    April 30, 2015

    Next week’s UK general election falls at a critical time for small and micro-businesses, with cogs moving at EU level as parties wrangle over the possibility of, and justification for, a threshold on VAT paid on B2C e-services.

  • HMRC faces legal action over LDF handling

    April 30, 2015

    UK revenue authority HM Revenue & Customs (HMRC) could face a judicial review over the way it used the Falciani list, and its Liechtenstein Disclosure Facility (LDF) tax amnesty.

  • The Brockman brief: Timing symmetry is shattered: CbCR and TP documentation

    April 28, 2015

    May’s instalment of his column sees Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, look at the problems that may arise for taxpayers given the timing differences applicable for different documentation and reporting requirements, and what options are available for reconciling these.

  • Tax planners' task tougher than ever

    April 28, 2015

    Failing to plan is planning to fail. We are all familiar with the phrase. But practising what one preaches in this regard has never been more important for corporate taxpayers.

  • EC launches infringement procedure against 3% dividend distribution tax, but it may not help French taxpayers

    April 21, 2015

    The European Commission (EC) has launched an infringement procedure against France concerning its 3% tax on dividend distributions by companies liable for French corporate income tax.

  • Franco-German double tax treaty changes have unexpected hit on real estate

    April 17, 2015

    Changes to the double tax treaty (DTT) between France and Germany have unexpectedly affected real estate investment trusts (REITs).

  • HSBC under criminal investigation in France

    April 15, 2015

    France has opened a formal criminal investigation into HSBC’s Swiss subsidiary, and will also probe the financial institution’s global holding company.

  • After Heritage, Total now in dispute with Ugandan tax authorities

    April 02, 2015

    French taxpayer Total is the latest oil company to be drawn into dispute with the tax authorities in Uganda.

  • World Tax and World Transfer Pricing 2016: The research period is now open

    April 02, 2015

    Don't miss out on your chance to be included in International Tax Review's directories of the leading tax and transfer pricing firms around the world.

  • EU’s cross-border VAT pilot scheme extended again

    April 01, 2015

    The EU is extending its cross-border rulings project pilot until September 30 2018.

  • March 2015

    European Tax Awards 2015 - the shortlists are out

    March 30, 2015

    The nominees have been revealed for International Tax Review's European Tax Awards 2015.

  • The Brockman brief : TP risk determination: Transparency and mutuality

    March 25, 2015

    This month, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, runs the rule over issues of transfer pricing risk determination, focusing on transparency and the benefits of increased levels of authority reciprocity.

  • Free-for-all: HMRC’s data-sharing relating to offshore assets

    March 25, 2015

    John Cassidy, tax investigations partner at Crowe Clark Whitehill in London, looks at trends in information sharing, and whether there will be any limits to the use of UK authority powers when it comes to data-sharing on offshore assets.

  • E-books judgment prompts calls for EU VAT reform

    March 25, 2015

    Ministers of culture from France, Germany, Italy and Poland have demanded the EU evolves its legislation to allow e-books to be taxed in the same way as physical books.

  • European Commission unveils tax transparency measures and makes automatic exchange of information central to combating evasion

    March 19, 2015

    The European Commission is promoting its Tax Transparency Package, published yesterday (March 18), as a tool for “healthier” tax competition as well as for helping member states identify abusive tax practices.

  • Dan Friel is new King & Spalding partner

    March 16, 2015

    Dan Friel has joined King & Spalding in London, becoming the third partner in the international tax practice there.

  • Goods vs services: ECJ rules against France and Luxembourg in e-books dispute

    March 06, 2015

    The European Court of Justice (ECJ) has ruled that France and Luxembourg cannot apply a reduced VAT rate to e-books, despite a reduced rate being acceptable for physical books.

  • ECJ delivers positive judgment in de Ruyter case

    March 04, 2015

    The European Court of Justice (ECJ) has ruled in favour of the taxpayer in the de Ruyter case, finding the French social charges on source property income for foreign tax residents to be against EU principles.

  • MOSS registration figures lower than expected

    March 04, 2015

    Around 7,000 businesses have registered for the EU’s VAT mini one-stop shop (MOSS) – far fewer than expected.

  • February 2015

    EU VAT rules causing thousands of businesses to close

    February 28, 2015

    A new report has shown that thousands of businesses across the EU are being forced into closure by the EU’s VAT rules governing the place of supply for e-services, introduced this year.

  • The Brockman brief: Interest: Double taxation equality is fading

    February 24, 2015

    In the first of his regular monthly updates, Keith Brockman, global tax director at Mars, lecturer and author of the Strategizing Multinational Tax Risks blog, looks at why countries are enacting unilateral legislation to limit interest deductibility, the shift in focus from eliminating double taxation to eliminating non-taxation, and why, as a result, double taxation via interest limitations is here to stay.

  • Cheers! Celebrate the world's top transactional firms

    February 24, 2015

    International Tax Review analyses global M&A trends from the past year and highlights the leading firms for tax transactional advice by jurisdiction.

  • HMRC and Serious Fraud Office collaboration shows UK policy shift

    February 20, 2015

    UK revenue authority HM Revenue & Customs (HMRC) will work with the Serious Fraud Office (SFO) to identify corrupt payments by looking at leaked Swiss tax records.

  • Real estate structuring in France in light of changes to the France-Luxembourg tax treaty

    February 18, 2015

    Incoming changes to the provisions of the France-Luxembourg tax treaty should not cause too much concern for taxpayers, who will still have means for tax efficient real estate structuring in France.

  • HMRC to work with Serious Fraud Office after PAC fireworks

    February 12, 2015

    The UK revenue authority, HMRC, will work with the police and the Serious Fraud Office (SFO) on leaked HSBC files showing that the bank helped clients avoid tax, after coming under pressure from members of parliament (MPs).

  • Romania mulls VAT cut

    February 06, 2015

    Romanian Prime Minister Victor Ponta has announced his intention to ease the VAT burden on the country’s taxpayers in 2016, either by reducing the headline rate from 24% to 21%, or by increasing the number of goods and services that come under the 9% reduced rate.

  • Jorge Correa Cervera moves to Creel

    February 04, 2015

    Creel, García-Cuéllar, Aiza y Enriquez has announced the hire of Jorge Correa Cervera as a partner in the firm’s tax practice.

  • UK wins Marks & Spencer cross-border relief case against Commission

    February 04, 2015

    The European Court of Justice (ECJ) has ruled that the UK’s cross-border relief rules are compatible with European legislation, and threw out the European Commission’s (EC’s) case against the country.

  • January 2015

    Finance ministers make fresh start on FTT

    January 30, 2015

    The 11 EU member states involved in the financial transaction tax (FTT) aim to broaden its base and lower its rates, in a bid to get the initiative back on track.

  • E-commerce and fixed establishment for VAT purposes: Important decision given by ECJ

    January 29, 2015

    The ECJ has provided innovative and factual precisions to the technical debate on fixed establishment around article 44 of the VAT directive, relating specifically to fixed establishment in the context of an e-commerce activity, in Welmory v Dyrektor Izby Skarbowej w Gdansku (C-605/12).

  • BEPS – Preventing treaty abuse: A practical perspective

    January 27, 2015

    Keith Brockman, global tax director at Mars and author of the International Tax Best Practices blog, analyses BEPS Action 6 on preventing treaty abuse, calling for more balance in seeking to avoid double taxation and double non-taxation, and more guidance on the interplay between domestic law and treaty interaction.

  • Mariano Giralt: Global custodian and acronym-buster

    January 27, 2015

    The landscape of international taxation is changing. The OECD’s BEPS project is likely to rewrite the rules governing international taxation in a way that has not been seen since the League of Nations shaped existing rules in the 1920s. A key component of this is taxation of the financial sector. Various sector-specific tax laws have been proposed. This is providing those in the sector with plenty to think about. One such figure is Mariano Giralt, Managing Director, Tax Services, at BNY Mellon. He talks to Matthew Gilleard about some of the key tax developments impacting financial services.

  • In taxpayers' sights: What to look out for in 2015

    January 27, 2015

    With multilateral projects due for final delivery, and many of 2014’s key themes lingering on, 2015 comes with a lot of unfinished business.

  • Full plate for taxpayers seeking certainty in 2015

    January 27, 2015

    With multilateral projects reaching their climax in 2015, the year ahead is sure to be filled with moments that define the future direction of international taxation. Matthew Gilleard highlights some of the major trends taxpayers should be looking out for in 2015.

  • Indirect tax: Innovation, energy, and e-commerce

    January 27, 2015

    As global communications become more efficient, developing countries are fast-tracking their progress to becoming global economies – with VAT and excise tax reforms a crucial part of that process. Meredith McBride speaks with indirect tax leaders to pinpoint the issues that will have taxpayers and their advisers scratching their heads in 2015.

  • Moving goalposts mean taxpayers must stay on toes

    January 27, 2015

    Joe Stanley-Smith analyses how new attitudes and initiatives from tax authorities in key jurisdictions will influence the national and international tax dispute landscape in 2015.

  • Moscovici rules out minimum VAT threshold

    January 23, 2015

    Pierre Moscovici, European Commissioner for Economic and Financial Affairs, Taxation and Customs, has ruled out implementing a minimum threshold for VAT paid on e-services, broadcasting and telecommunications.

  • Small businesses rail against VAT MOSS changes

    January 21, 2015

    Small and micro-businesses have spoken out against this year’s EU changes to the place of supply for e-services, telecommunications and broadcasting.

  • EU VAT: Implementation going well so far, says Raponi

    January 15, 2015

    The implementation of the new EU system for VAT payment is going well, despite minor hiccups for Germany and the Netherlands, and complaints from UK businesses.

  • New year, new start: Moves, mergers and promotions of 2015

    January 15, 2015

    The start of each year is often a time when firms choose to announce promotions, mergers and more.

  • De Lamy and Irvine promoted at Weil, Gotshal & Manges

    January 12, 2015

    Edouard de Lamy has been made a partner and David Irvine has become a counsel as part of Weil, Gotshal & Manges’s new year promotions.

  • EU Parliament and Council agree on beneficial ownership registers

    January 07, 2015

    EU Parliament and Council negotiators have agreed a draft directive which would introduce beneficial ownership registers in Europe for the first time.

International Tax Review Profile

RT @AuroChardon: Let's honour the #memory of a brave #journalist and woman ➡️ vigil tomorrow, 18 Oct, 6pm, in front of Residence Palace #Da…

Oct 18 2017 04:42 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Big Soda scores victory as Chicago-area tax repealed - could this be the beginning of the end of the sugar tax trend?https://t.co/PNuafWHy9K

Oct 12 2017 04:03 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Ebay and Netflix pay total UK tax of less than £1.9m - How long until HMRC investigate their TP practices? https://t.co/VPPsT3aGMZ via @FT

Oct 12 2017 03:59 ·  reply ·  retweet ·  favourite
International Tax Review Profile

Panama Papers: German authorities carry out first raids in connection with tax leaks https://t.co/LgalVGGw0x via @dwnews

Oct 12 2017 03:49 ·  reply ·  retweet ·  favourite
International Tax Review Profile

RT @ScoopOnTaxes: @Skynet This will not end well for humanity. https://t.co/jsxVwDoDc5

Oct 11 2017 12:02 ·  reply ·  retweet ·  favourite
International Correspondents