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France Tax News

French Parliamentary response on non-eligibility of Luxembourg SICARs to France-Luxembourg tax treaty and EC Parent Subsidiary Directive

12 November 2006

Protocol to treaty between Luxembourg and France – immovable property and business profit provisions amended

12 September 2006

Treaty negotiations between France and Japan finalized

12 September 2006

Treaty between Australia and France – details

13 August 2006

Treaty between Chile and France enters into force

13 August 2006

European Commission requests Belgium to terminate discriminatory taxation of inbound dividends

13 August 2006

Guideline on French withholding tax applied to certain interest income published

13 August 2006

Indian ruling that commission paid to non-residents are taxable in India even if the services are provided outside India

13 August 2006

European Commission requested Spain to end infringement to the EC Parent-Subsidiary Directive concerning the use of anti-abuse measures

13 August 2006

European Commission decides that Luxembourg's preferential tax regime for 1929 holding companies constitutes incompatible state aid

13 August 2006

Treaty between France and Netherlands – Code of Conduct (MAP)

13 August 2006

European Commission requests Belgium, Italy, Luxembourg, Netherlands, Portugal and Spain to terminate discriminatory taxation of outbound dividends

13 August 2006

European Commission refers Italy and Luxembourg to ECJ for not implementing Directive amending EC Parent-Subsidiary Directive

13 August 2006

Treaty between France and Chile ratified

11 July 2006

Treaty between Australia and France signed

11 July 2006

Treaty between Peru and France – negotiations

14 June 2006

Luxembourg Court

14 May 2006

US Senate ratifies protocols to income and capital, and estate, inheritance and gift, tax treaties between France and US

14 May 2006

Preliminary ruling requested from ECJ on compatibility of 3% tax on French immovable property held by non-resident companies with EC freedom of establishment and free movement of capital movement

14 May 2006

Guideline on pre-approval of favourable regime for transfer of complete branches of activity

14 May 2006

US Foreign Relations Committee approves protocols to income and capital, and estate, inheritance and gift, tax treaties between France and US

9 April 2006

Modifications to participation exemption regime

16 March 2006

US

16 March 2006

It has been reported that France will begin official negotiations with Japan on 25 January 2006 to revise the France-Japan income tax treaty of 3 March 1995. The main purpose of the revision is to encourage more bilateral investments by lowering the withholding tax rates which are currently fixed at 15% for dividends (5% for qualifying companies), 10% for interest and 10% for royalties

19 February 2006

Finance Law 2006 published

19 February 2006

French Guideline on treaty treatment of Canadian mutual funds in securities published

19 February 2006

French Court of Appeals decision on debt waivers granted to branches of foreign subsidiary by French parent company published

19 February 2006

The US Tax Court has disallowed a deduction for a contribution to a French pension plan and payment of French real estate taxes. Isabelle Bichindaritz v. Commissioner of Internal Revenue (T.C. Memo 2005-298 dated 29 December 2005). The case involved a French citizen who was teaching at a US university. She claimed a deduction on her US tax return for a contribution to a French pension plan and also a deduction for the payment of French real estate taxes.

19 February 2006

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19 February 2006

It has been announced by the German Federal Ministry of Finance that negotiations are ongoing for a new protocol to the income and capital tax treaty of 21 July 1959 between Germany and France. Further details of the treaty will be reported subsequently.

19 February 2006

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