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