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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 ‘dependent agent’.
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 significant shareholding in a French entity.
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.
