The Finance Bill for 2024 provides for the content of transfer pricing documentation to be enforceable against taxpayers. To fully appreciate the significance of this measure, we need to put it into perspective with two other provisions. Firstly, the bill also envisages lowering the thresholds for [...].

FACTS Howmet SAS is part of a group headquartered in Luxembourg. Together with its French subsidiary, it forms a tax consolidation group. With a view to completely overhauling its financial organization, the group undertook a succession of restructuring operations in a very short space of time, with the aim of bringing [...]

START-UP SITUATION SAP France is indirectly owned by the German company SAP AG. Under a contract dated 2009, SAP France entered into a centralized cash management agreement with its parent company, under which it deposited its cash surpluses with the German company, which [...].

The SAS Willink issued two ten-year bonds convertible into shares at an interest rate of 8% p.a., subscribed by two French venture capital funds and a British company. ADMINISTRATIVE OVERSIGHT The tax authorities questioned the [...]

STMicroelectronics carries out R&D in the field of semiconductor technologies, for which it receives a research tax credit. It has signed a framework agreement with its parent company, STMicroelectronics NV, under which STMicroelectronics carries out R&D operations on behalf of STMicroelectronics NV.

START-UP SITUATION WB Ambassador took out two loans with its parent company and another group company, bearing interest at an annual rate of 7%. The tax authorities considered this rate excessive in the light of combined articles 212-I and 39-1-3 of the French General Tax Code, and consequently proposed a correction by adding back [...].

Certain sea serpents reappear every time you stir the bottom of the most stagnant ponds. Such is the case with tax niches, once again put back on the chopping block at a time when the first assessments highlight an explosion in public spending and economic forecasts that are even more gloomy than expected. At the same time [...]

Source : www.ieepi.org IEEPI gives the floor to its experts, today Terence Wilhelm, lawyer and founder of the law firm CARA Société d'Avocats, specializing in international taxation, transfer pricing and intellectual property taxation. He offers us an analysis of : The new preferential regime applicable to patents and industrial property rights [...]

Once again this year, statistics from the World Tourism Organization reassure us on one point: France remains the world's leading tourist destination, far ahead of its European competitors and the United States. Travelers from all over the world come to our roads to admire the architectural wonders that embellish our cities, to taste the diversity of our culinary delights and to [...]