OrbitaxFrench Court of Appeal Rules Horizontal Group May Not be Formed by Companies Held by Swiss Parent Despite Treaty Non-Discrimination Clause
|Approved Changes|France
The Administrative Court of Appeal of Paris issued a decision on 1 March 2024 concerning whether subsidiaries in France of a Swiss parent company may form a horizontal integrated tax group. Under French law, French companies may generally form a horizontal group if at least 95% held by a French parent. Subject to certain conditions, this also extends to cases where the parent is resident in ano…
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