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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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties