In a decision dated November 3 2003 (Conseil d'Etat, 244437, SARL Meridia France), the French Administrative Supreme Court had to decide whether the interest paid by a French company to a partner domiciled abroad as current account remuneration may benefit from the withholding tax exemption provided by section 131(4) of the French tax code
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The EU has seemingly capitulated to the US’s ‘side-by-side’ demands. This may be a win for the US, but the uncertainty has only just begun for pillar two
ITR’s most prolific stories of the year charted public pillar two spats, the continued fallout from the PwC Australia tax leaks scandal, and a headline tax fraud trial
The climbdowns pave the way for a side-by-side deal to be concluded this week, as per the US Treasury secretary’s expectation; in other news, Taft added a 10-partner tax team