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.
