The government plans new measures in favor of the CIR (French R&D tax credit)
Taj
by adubly
1M ago
As part of its simplification action plan for companies, the government has unveiled a number of measures of interest to R&D players. Acceleration of the payment of the CIR The government plans to create a dedicated mission to study the CIR instruction and payment chain. The objective is for 2/3 of CIR repayments to be made within less than 3 months. CIR certification: soon to be faster? The processing times for CIR certification application (agrément) are currently very long – 12 months on average – and it is not exceptional that the approval of a subcontractor for the 2023 CIR (filed in ..read more
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CIR – Details on the young PhD regime
Taj
by Raphaël Blanchard
1M ago
The Council of State judges that staff already hired on a permanent contract (CDI), then holding a doctorate, benefit from the young PhD regime, during the first 24 months from their hiring (and not from the date of obtaining their doctorate), regardless they have not signed an amendment to their employment contract. The story Under the terms of article 244 quarter B, II, b of the General Tax Code, personnel expenses relating to personnel holding a PhD, directly and exclusively assigned to research operations, are taken into account for twice their amount during the first 24 months following t ..read more
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Administrative Supreme Court rules final foreign branch losses may not be deducted
Taj
by adubly
1M ago
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French Administrative Supreme Court ruled on 26 April 2024 that the taxable result of a French group could not take into account the final losses of the group’s Luxembourg branch (Conseil d’Etat, n° 466062). Background and facts of the case A French company belonging to a tax consolidated group requested that the final losses incurred by its Luxembourg branch be included in its taxable result for 2015, the year the branch was liquidated. This claim was based on the 2005  ..read more
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Court clarifies full 20% tax credit applies to royalties under France-Tunisia treaty
Taj
by adubly
1M ago
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French Conseil d’Etat (Administrative Supreme Court) ruled on 19 February 2024 that the allocation of a tax credit for patent royalties paid by a Tunisian payer to a French company that are subject to withholding tax in Tunisia, is not limited to the amount of French tax imposed on those royalties (Conseil d’Etat, 19 February 2024, n° 469407, available in French only). Background and facts of the case Under the provisions of article 19 (royalties) of the France-Tunisia treaty ..read more
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Paris 2024 Opening in Less Than 100 Days – Streamline Visa Applications and Processing Time
Taj
by adubly
3M ago
Less than 100 days to go until the opening of the Olympic/Paralympic games, visa sections around the world will have to process an increased number of visa applications in addition to the summer peak season. What’s the change? The visa applications will be processed differently depending on the status of the applicants intending to visit France for the participation or the attendance to the Olympic/Paralympic Games. Indeed, the French “Olympic Consulate”, set up early in January, is in charge of specific visa applications. In this regard, there are 3 main categories of visa applications: Olym ..read more
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Horizontal consolidation is not contrary to nondiscrimination clause in tax treaty
Taj
by adubly
3M ago
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The Administrative Court of Appeal of Paris ruled on 1 March 2024 that the French horizontal tax consolidation regime is not contrary to the nondiscrimination clause of the France-Switzerland tax treaty. Background and facts of the case As a reminder, the French horizontal tax consolidation regime was introduced in France in 2014, following the decision of the Court of Justice of the European Union in SCA Group Holding and Others (12 June 2014, joined cases C-39/13, C-4 ..read more
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2024 French Finance Bill: a Focus on HTVI Related Measures
Taj
by adubly
4M ago
The 2024 French Finance Bill, officially known as law n°2023-1322, was passed on December 29, 2023. It brings in new regulations aimed at strengthening the requirements for transfer pricing documentation and empowering the French Tax Authorities (FTA) to oversee transactions involving Hard-To-Value Intangibles (HTVI). This bill introduces three key measures concerning HTVI: Allowing the FTA to use ex-post financial data to assess the value of HTVI. Extending the statute of limitation period for HTVI-related transactions from 3 to 6 years (the standard limitation period in France). Granting th ..read more
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Management and collection of the “employer tax” transferred to the tax administration
Taj
by adubly
4M ago
What is the change? Pursuant to the Finance Law n°2022-1726 dated December 30th, 2022, for 2023, the transfer of the management and collection of “employer tax” from OFII (Immigration Office) to the tax authorities (DGFIP) took effect on January 1, 2023. As a reminder, the liable party is an employer who hires foreign workers or hosts seconded employees to France for a salaried professional activity. The tax applies upon their first admission to France. The hiring of EU nationals is exempted from this employer tax. Since the tax is to be declared and paid annually in arrears, the first formali ..read more
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2024 French Finance Bill: Enhanced Oversight Targeting Transfer Pricing
Taj
by adubly
4M ago
The 2024 French Finance Bill (law n°2023-1322) was adopted on December 29, 2023, and has introduced new measures reinforcing transfer pricing documentation requirements as well as the power of control by the French tax authorities (FTA) of transactions related to hard-to-value intangibles. French Tax Reforms: tighter transfer pricing documentation Rules and enhanced possibilities for the FTA to audit and adjust hard-to-value intangibles (HTVI) related transactions Transfer pricing documentation requirements have been amended: by lowering to €150 million (instead of €400 million previously) th ..read more
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List of noncooperative states and territories updated (February 2024)
Taj
by adubly
4M ago
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s list of noncooperative states and territories (NCSTs) was updated on 17 February 2024 to add Antigua and Barbuda, Belize, and Russia and to remove the British Virgin Islands. The Ministry of Finance updates the NCST list every year. As a reminder, since 1 January 2010, defensive tax measures apply to jurisdictions on the list, including, for example, the non-application of the French participation exemption regime, increased withholding taxes on outbound payments, and th ..read more
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