Mathis Rossignol and Nicolas Duboille of Sumerson explain how the decisions clarify the scope of France’s anti-avoidance regime for foreign entities, while raising new questions for internationally mobile individuals and cross-border holding structures
Nicolas Duboille and Mathis Rossignol of Sumerson explain how France’s new withholding tax mechanism reshapes access to treaty relief and creates significant cash-flow and compliance implications
Nicolas Duboille and Mathis Rossignol of Sumerson analyse the far-reaching implications of a French Supreme Administrative Court decision clarifying the application of Article 123 bis of the General Tax Code
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 Riccio of Sumerson explain.
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 efficient from a tax and social contribution perspective.
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.
