Sumerson

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.