France–MNE Tax

Americas

French and German finance ministers voice support for US proposal on global minimum tax: Reuters→

April 28, 2021

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

Europe

EU court rejects Swedish rules limiting deductions for cross-border interest payments

February 24, 2021

Emiliha Ferrão, a transfer pricing specialist at Thorning Koponen Consulting in Stockholm, Sweden, discusses the implications of a European Court of Justice ruling, issued January 20, on Swedish tax rules that limit deductions for some cross-border interest payments . . .

G7 leaders reaffirm commitment to reach international tax agreement

February 23, 2021

G7 leaders reaffirmed their commitment on February 19 to reach an agreement by mid-2021 on new international tax rules. During a first leaders’ meeting under the UK’s G7 presidency, the Group of Seven resolved to . . .

Austria

Trade groups sue over Maryland’s controversial tax on digital advertising

February 22, 2021

Four organizations have joined in a lawsuit challenging a new Maryland state law levying a tax on digital ad revenue – the latest twist in an ongoing dispute with international implications. The US Chamber of Commerce, the . . .

Americas

Report estimates effective tax rates on investment in the EU member states, North Macedonia, Turkey, UK, Norway, Switzerland, Canada, Japan, and US: EU Commission→

February 19, 2021

Americas

In a call with French finance minister Bruno Le Maire, US Secretary Janet Yellen committed “to re-engage actively in the ongoing OECD discussions on international taxation to forge a timely international accord”: US Department of the Treasury→

January 28, 2021

Europe

Ferragamo France’s transfer pricing dispute and resale price method abuse

January 25, 2021

Dr. J. Harold McClure, a New York City economist, notes that a recent transfer pricing case decided by France’s Supreme Administrative Court appears to involve a distribution affiliate with persistent operating losses despite purporting to use arm’s length margins, a pattern discussed in detail by Dr. Ednaldo Silva in his January 6 MNE Tax article . . .

Americas

US says Austria, Spain, UK digital taxes discriminate, warns on EU tax, three others

January 15, 2021

Digital services taxes enacted in Austria, Spain, and the UK discriminate against US companies within the meaning of Section 301 of the US Trade Act of 1974, the Office of the US Trade Representative . . .

Americas

US says Italy, India, Turkey digital services taxes are discriminatory, suspends France tariff action

January 7, 2021

Digital services taxes enacted in India, Italy, and Turkey discriminate against the United States; however, for now, no trade actions will be taken, the Office of the US Trade Representative . . .

Digital Economy

French High Court in Valueclick interprets tax treaty permanent establishment rules

January 5, 2021

Mickael Duquenne, Senior Manager and Pascal Luquet, Partner, at Grant Thornton Société d’Avocats, Paris, discuss a December 11 landmark decision of France’s Supreme Administrative Court concluding that an Irish company had a permanent establishment in France . . .

Africa

OECD publishes details on 40 countries’ uptake of transfer pricing rules for hard-to-value intangibles

December 16, 2020

The OECD today published 40 responses to a questionnaire that asked officials whether their country has adopted transfer pricing rules for . . .

Americas

France to request EU retaliation if US enacts trade sanctions in response to French digital services tax, Le Marie says: Reuters→

December 2, 2020

Americas

France cancels suspension of digital service tax collection, sends Facebook, Amazon, other large tech firms tax bills due in December: Reuters→

November 25, 2020

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Europe

Commission asks France to change taxation of foreign investment fund capital gains arising from sales of French company shares: EU Commission→

November 2, 2020

Americas

France reinstates digital tax, courting trade war: Bjarke Smith-Meyer & Elisa Braun / POLITICO→

October 14, 2020

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

September 23, 2020

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Americas

France says US blocking global digital tax talks: Reuters→

September 10, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Digital Economy

Facebook agrees to pay France USD 118m for 2009–2018 back taxes, advises it began reporting advertising revenue in France from 2019: Mathieu Rosemain / Reuters→

August 25, 2020

Asia-Pacific

UK guidance updated to state that France, Italy, Malaysia, Turkey taxes are similar to UK’s digital services tax for purposes of cross-border relief: HM Revenue and Customs→

August 5, 2020

Americas

US Republican and Democrat Senate leaders reiterate support for retaliatory tariffs on France if DST not repealed: The United States Senate Committee on Finance→

July 14, 2020

Americas

US imposes 25 percent tariff on USD 1.3b French luxury goods in retaliation for French DST but suspends tax for up to six months: Doug Palmer / Politico→

July 11, 2020

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Americas

Professor advocates worldwide digital tax based on country-specific income thresholds but subject to a worldwide de minimis amount: Assaf Harpaz / SSRN→

June 8, 2020

Denmark

EU Commission spokesperson says states can’t deny COVID-19 relief to firms headquartered in tax havens: Nikolaj Nielsen / euobserver→

May 8, 2020

Denmark

France joins Denmark and Poland in barring firms headquartered in tax havens from coronavirus support measures: Bill Bostock / Business Insider→

April 26, 2020

Austria

OECD publishes reports on cross-border tax dispute resolution Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

April 10, 2020

The OECD on April 9 published stage 2 reports approved by the “Inclusive Framework on BEPS,” an OECD-led body of 135+ countries, that assess the cross border tax dispute resolution procedures . . .

Europe

France enacts emergency tax measures in response to coronavirus epidemic

March 18, 2020

Pascal Luquet and Mickaël Duquenne of Grant Thornton Société d’Avocats, Neuilly-sur-Seine, discuss emergency tax measures, announced by the French General Directorate of Public Finance, enacted in response to the coronavirus epidemic. . .

Americas

French minister announces US-France digital tax deal: through December France will impose but delay collection of DST, US will delay imposition of retaliatory tariffs: Pan Pylas & Jamey Keaton / AP→

January 22, 2020

Americas

France to delay DST, US to delay tariffs to allow more time for international tax deal, unnamed French officials say: James Politi, Mehreen Khan, Victor Mallet, & Martin Arnold / Financial Times→

January 21, 2020

Americas

US proposal for optional pillar one tax is a “non-starter” French minister says: Reuters→

January 17, 2020

Americas

EU trade Commissioner Phil Hogan in US this week as digital tax dispute heats up: Doug Palmer / POLITICO→

January 13, 2020

American Samoa

France’s updated tax blacklist includes Panama Anguilla, Bahamas, Fiji, Guam, BVI, Oman, American Samoa, Samoa, Seychelles, Trinidad and Tobago, US Virgin Islands, Vanuatu: Rosemont International→

January 9, 2020

Americas

To avert trade war, US and France agree to seek digital tax compromise over the next 15 days: William Horobin & Laura Davison / Bloomberg→

January 7, 2020

Americas

Any US trade action over French DST would lead to retaliation and WTO challenge, minister warns: Reuters→

January 6, 2020

Austria

Germany, France, Italy, seven others, supporting plan for EU tax on stock trades of a minimum of .2% of transaction value: Patricia Kowsmann / Wall Street Journal→

December 11, 2019

Americas

France will challenge at WTO any US tariffs imposed in retaliation for DST, Finance Minister says: Geert De Clercq / Reuters→

December 11, 2019

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin