Sumerson

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.