Blog of AlterTax, law firm
Welcome to our tax blog, an invaluable resource for anyone seeking to navigate the complex and ever-changing world of taxation.
Whether you’re a seasoned finance professional, an entrepreneur managing the tax realities of your business, or simply an individual looking to optimize your tax situation, our blog offers valuable insights, practical advice and in-depth analysis.
Multinationals: New Income Tax Rules in 2024
From June 22, 2024, multinationals will be subject to new income tax reporting requirements. Transposing European Directive 2021/2101 on public CbCR, Order no. 2023-483 introduces these major changes.
Finance Law 2024: Tax Control and Transfer Pricing
The Finance Bill for 2024 brings major changes to the tax auditing of multinational companies. These changes, particularly with regard to transfer pricing controls, are designed to step up the fight against tax fraud and improve transparency in intra-group transactions.
Delivery of goods: when is it taxable in France?
VAT, or Value Added Tax, is a crucial tax for businesses in France. However, its application depends on the place where the commercial transactions are deemed to take place. For deliveries of goods, territoriality rules vary depending on the situation.
Where are certain services taxed?
Tax auditing is already a complex process, but when it involves companies belonging to an integrated group, things can get even trickier.
Pacte Dutreil and family businesses: a winning combination!
The Dutreil pact is a scheme for transferring a business, usually a family business, with a partial exemption of up to 75% of the free transfer tax.
The taxable amount of free transfer duties will therefore be calculated on 25% of the value of the securities sold.
France’s tax police: towards a repressive tax policy
The fight against tax fraud has become a major preoccupation for tax authorities in France. In response to this problem, the government has introduced a new tool: the tax police. This measure is an important step in the crackdown on tax crime, which is becoming increasingly severe. In this article, we’ll look at the introduction of the tax police in France and its impact on tax policy, as well as the importance of calling on the services of a tax lawyer specializing in criminal tax matters.
Tax inspection: how does the Administration check your tax returns?
Paying taxes is a legal obligation for all taxpayers. However, it is important to know that the tax authorities can check taxpayers’ tax returns for compliance.
What is the annual 3% contribution on real estate?
Legal entities that own real estate in France are subject to a tax of 3% on the value of their properties. This tax on the fair market value of real estate was introduced by the 1983 Finance Law with the objective of ensuring visibility of the chains of ownership of properties by French and foreign entities, allowing the identification of shareholders and thereby verifying the proper application of the Wealth Tax (ISF), now replaced by the Real Estate Wealth Tax (IFI).
Control of registration fees by the tax authorities
This control can generally lead to a rectification of the prices or valuations used in documents subject to the registration formality (these are numerous and include transactions involving movable and immovable property (gifts, transfers, inheritance in particular, but also IFI).
What debts are deductible under the IFI?
Debts on taxable (real estate) assets are deductible from the value of these assets for IFI purposes. However, this deductibility is excluded by law if the debts are not related to taxable real estate assets. This is the case, for example, for debts incurred to maintain the family’s lifestyle, to acquire non-taxable assets (such as a business) or exempt assets (such as premises used by a taxpayer for professional purposes).
Home visits based on mere suspicion of tax fraud
In two rulings handed down on February 15, 2023 (Cass. com., February 15, 2023, no. 20-20.599 and Cass. com., February 15, 2023, no. 20-20.600), the Commercial Chamber of the French Supreme Court confirms that the tax authorities can initiate home visits against a taxpayer on the basis of mere suspicions of tax fraud.
What is the 3% annual contribution on buildings?
Legal entities owning real estate in France are liable for a 3% tax on the value of this real estate.
This 3% tax on the market value of real estate was introduced by the 1983 Finance Act, with the aim of ensuring the visibility of chains of real estate ownership by French and foreign entities; making it possible to obtain the identity of associates and thus verify the correct application of the wealth tax (ISF), now replaced by the real estate wealth tax (IFI).
Tax consolidation: taking into account cross-shareholdings between subsidiaries
Faced with inflation, the energy crisis and environmental challenges, there is a strong temptation to implement general or targeted VAT cuts. However, in its report on VAT, the Conseil des prélèvements obligatoires (CPO) points out that these reduced rates are costly for public finances, economically inefficient and rarely evaluated. Explanations.
VAT: towards the end of reduced rates?
Faced with inflation, the energy crisis and environmental challenges, there is a strong temptation to implement general or targeted VAT cuts. However, in its report on VAT, the Conseil des prélèvements obligatoires (CPO) points out that these reduced rates are costly for public finances, economically inefficient and rarely evaluated. Explanations.
How should Canadian trust assets be taxed?
For several years now, the French tax authorities have been looking into a number of cases of potential tax fraud involving large French fortunes. They are said to have used Canadian trusts, via the Blue Bridge wealth management company, to evade French wealth tax.
However, in ruling no. 21/10189 of February 6, 2023, the Paris Court of Appeal held that the assets of a Canadian trust were only taxable in Canada and not in France, thus ruling out the possibility of tax fraud. Explanations.
Resources
French rights
Transfer pricing (art 57 CGI)
Transfer pricing documentation
Public finance website
Transfer pricing declaration form
CBCR form
Transfer pricing guide for SMEs
Technical resources
Transfer Pricing In France
OECD Transfer Pricing Guidelines
Fiscalité internationale
Overview of the French tax system
France’s international tax treaties
International law
Tax definitions
Taxation concerns the methods used by governments to collect revenue, mainly through taxes. This section clarifies these concepts, explaining the different types of tax and their impact on individuals and businesses.
Tax obligations
Tax obligations Any entity or individual subject to a given tax jurisdiction must comply with rules and procedures defined by law, commonly referred to as tax obligations. This responsibility...
Liquidation De L’Impôt
Liquidation De L'Impôt Understanding tax settlement is essential for any taxpayer or company wishing to meet its tax obligations efficiently and in compliance with current legislation. This article...
Indirect taxation
Indirect taxation Indirect taxation plays a key role in modern tax systems. It has a direct influence on the circulation of goods and services, as well as on household consumption, but is often less...
Direct Taxation
Direct Taxation When it comes to taxation, a basic but central concept isdirect taxation. This article looks at how it works, its characteristics and its impact on the taxpayer and the State. What...
Business expenses
Business expenses Business expenses play a major role in the financial management of companies and the self-employed. Knowing and being able to deduct these legitimate costs is essential for...
Tax exemption
Tax exemption Tax exemptions are an important lever in tax policy, enabling us to stimulate the economy, favor certain sectors of activity or support households and businesses in specific...
Tax domicile
Tax domicile Domiciliation is a key concept in the field of taxation. It determines the country in which an individual or legal entity is subject to tax. This concept is essential to understand for...
Tax Return
Tax Return The tax return is a must for many taxpayers. It is used as the basis for calculating income tax, and for declaring income received during the previous tax year to the tax authorities....
Tax Base
Tax Base The world of taxation is littered with technical terms, among which "tax base" is a central concept. This key element determines the extent of the tax contribution applied to both...