France: Supreme Court clarifies company residence relating to DTT benefits The French Administrative Supreme Court issued a judgment in February that clarifies the assessment of company residence for access to double tax treaty (DTT) benefits, as Nicolas Duboille and Clément... By Nicolas Duboille & Clément Riccio April 07 2022
The legal uncertainty surrounding management packages in France and prospective solutions Further to recent case law, Nicolas Duboille and Hugo Levit of Sumerson, discuss the potential use of alternative legally bound tools in the context of management packages that may be... By Nicolas Duboille & Hugo Levit March 03 2022
France: Taxation of real estate capital gains and the questionable outcome of the Frenc... Nicolas Duboille and Hugo Levit of Sumerson examine the taxation of real estate capital gains in France by non-residents and consider a case when the seller is a Delaware corporation. By Nicolas Duboille & Hugo Levit September 30 2021
France: Special expatriate tax regime – a breath of fiscal oxygen under control Nicolas Duboille and Alexia Dal Ponte of Sumerson examine the French special expatriate tax regime enshrined in Article 155B of the French Tax Code, in the light of recent case... By Nicolas Duboille & Alexia Dal Ponte March 18 2021
Conseil d’Etat recharacterises the existence of a PE in the digital economy Nicolas Duboille and Hugo Levit of Sumerson analyse why the judges overturned the decision of the Paris Administrative Court of Appeal and ruled in favour of a broad interpretation of... By Nicolas Duboille & Hugo Levit February 02 2021
France: Twin cases reduce the scope of taxing capital gains on sale of French shares Nicolas Duboille and Alexia Dal Ponte of Sumerson analyse recent case law concerning the application of the French capital gain tax applicable to non-resident entities on the transfer of a... By Nicolas Duboille & Alexia Dal Ponte January 25 2021
France: The difficulty of applying anti-avoidance rules to trusts Nicolas Duboille of Sumerson looks at the decision in the Clive-Worms case, which confirms that anti-avoidance rules targeting undistributed profits realised in low-tax jurisdictions are not easily applicable to trusts. By Nicolas Duboille October 30 2020
Conseil d’Etat rules on French anti-avoidance rules related to low-tax jurisdictions Nicolas Duboille of Sumerson analyses recent judicial rulings put forward concerning the application of the anti-avoidance rule in France. By Nicolas Duboille August 31 2020
