June 27th 2014
The French administration has issued its instruction on the
taxation of non-resident capital gains on both immovables,
and shares in investment vehicles, such as RIETS which
represent immovables in France by non-residents...
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June 18th 2014
EFI reports that the French Government has just denounced the
1953 Succession Duty Treaty with Switzerland, a short time before
its Finance Minister's trip to Berne.
Do we need to concern ourselves with the French "change" in
policy in relation to...
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June 16th 2014
I will start from the depths and move up.
The French administration has seized the opportunity to attempt
to invalidate its prior doctrinal position on trusts in relation to
the new legislation:
Instruction BOI-ENR-DMTG-30-20121016 of 16th...
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June 16th 2014
Joined cases of X BV
(C‑24/12), and TBG Limited (C‑27/12)
v Staatssecretaris van Financiën. Ruling of
5 June 2014.
The case raises the issue as to whether a Member State,
here the Netherlands, can discriminate more or less...
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June 3rd 2014
Schrödinger's cat is now out of the bag of fiscal uncertainty in
relation to the use of the Maastricht freedom of movement of
capital by third country residents in relation to fiscal
impediments to free movement of capital. Articles 63 - 66...
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May 19th 2014
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May 19th 2014
One could be pardoned for wondering on which planet the French
administration thinks we, and indeed the Swiss, are.
Article 24 of the previous UK French DTT of 22nd May, 1968 stipulated an exemption for British
residents, not domiciliaries but...
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April 22nd 2014
There appear to be a number of advisors questioning
the extent to which the French Conseil d'Etat has invalidated
article 164C CGI in its judgement N° 360488 handed down on 26th
December 2013, applying a CJEU decision in
Yvon Welte Case...
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