Meeting for the third time in Rio on July 25 and 26, the G20 reaffirmed its strong commitment to fair global tax reform. The G20 continues to play a crucial role in reshaping the international tax system to meet the challenges posed by globalization and [...].

In recent years, article 39-1-3 of the French General Tax Code has become one of the best-known tax provisions. Like a kind of code, a digital password reserved for a community apart. We no longer speak of the deductible interest rate. We say "the 39-1-3 rate". Do [...]

FACTS FACTS Following an audit of GEII Rivoli Holding's accounts for the 2013 and 2014 financial years, the tax authorities questioned the deductibility of the difference between the 5.08% rate applied and the 2.79% rate corresponding to the value referred to in paragraph 3 [...].

Do the test around you: ask those around you to name several tax havens. It's more than likely that Russia isn't on the list of exotic, sulphurous states or financial centres that often immediately spring to mind and (sometimes wrongly) make the uninitiated nervous. And yet, on February 14 [...]

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 [...]

Published in Revue Européenne et Internationale du Droit Fiscal n° 2012/3 Read the full article

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 [...].