France–MNE Tax

Americas

US publishes US-France joint statement on implementation of spontaneous exchange of country-by-country reports on multinationals: US Treasury→

December 9, 2019

Americas

France rejects US plan to turn pillar one of tax rewrite into a “safe harbor,” says EU should negotiate digital tax if global agreement falls through: Tom Ozimek / Epoch Times→

December 9, 2019

Belgium

Latest EU effort to make country-by-country reporting public fails

December 3, 2019

Davide Anghileri of the University of Lausanne, Switzerland discusses a recent EU Council vote on a proposal to make public country-by-country reports on large multinationals . . .

Americas

US trade officials propose tariffs of up to 100 percent on French goods to counter digital services tax

December 2, 2019

The office of the United States Trade Representative (USTR) today proposed retaliatory tariffs of up to 100 percent on French wine, cheese, handbags, makeup, china, and similar items, after concluding that France’s digital services tax . . .

Americas

OECD’s digital tax plan would raise little revenue for France, Germany, US, and China, French Council of Economic Analysis concludes: Financial Times→

November 19, 2019

EU finance ministers urge adoption of aviation tax

November 11, 2019

Finance ministers from 9 European nations on November 7 called on the European Commission to advance a proposal for . . .

Americas

Unanimity not required to update global rules for taxing multinational groups, OECD’s Saint-Amans says

October 18, 2019

The OECD’s “pillar one” proposal to update the global rules for allocating multinational group profit and related taxing rights can be implemented even if . . .

Americas

US could still retaliate in response to French digital tax despite earlier suggestions of compromise: Bloomberg Tax→

October 17, 2019

Americas

France joins ICAP pilot to jointly assess MNE tax positions

September 18, 2019

France has joined the International Compliance Assurance . . .

Americas

US, France reach deal on digital services tax

August 26, 2019

French President Emmanuel Macron today confirmed that the US and France have reached a compromise agreement which requires . .

Americas

Discussion of France and UK digital tax expected to dominate G7 finance ministers meeting: France 24→

July 17, 2019

Americas

Google, Facebook, Amazon argue at US hearing that French digital tax unfairly targets US companies: Emily Birnbaum / The Hill→

August 20, 2019

Americas

Google, Facebook, Amazon to testify at US trade hearing on French DST: Reuters→

August 14, 2019

Americas

US to retaliate against France in response to digital tax, Trump says

July 26, 2019

President Donald Trump today announced in a tweet that the US will retaliate. . .

Americas

Industry group to file complaint with EU Commission alleging French digital tax is illegal State aid: Isabel Gottlieb / Bloomberg Tax→

July 30, 2019

Digital Economy

French digital services tax signed into law: Hamza Ali / Bloomberg→

July 26, 2019

Digital Economy

France’s lower house approves 3% digital services tax: ABC News→

July 7, 2019

Americas

House Ways and Means lawmakers urge US response to France’s digital tax proposal

June 20, 2019

US House Ways and Means Committee members . . .

Americas

US announces probe into France’s digital services tax

July 10, 2019

The US will investigate whether France’s digital services tax, expected to pass the Senate . . .

BVI, Bermuda, Cayman top tax haven list; UAE, UK, France most aggressive in lowering other countries withholding tax via treaty: Tax Justice Network→

May 29, 2019

Ten EU states considering German plan for .2% tax on purchases stock in EU headquartered companies: Reuters→

June 17, 2019

Asia-Pacific

Australia publishes synthesized text of tax treaties with France, Finland, Malta as altered by MLI

August 9, 2019

The Australian government on August 9 published the synthesized texts of . . .

Digital Economy

French National Assembly and Senate conference committee reaches agreement on digital services tax: French Senate (in French)→

June 30, 2019

Americas

In letter, US Senators Grassley and Wyden urge Treasury to use “all available tools” including Section 891, to stop France from enacting a DST: US Senate Committee and Finance→

June 24, 2019

Europe

France to end 1 billion Euros of business tax breaks to finance personal income tax relief, minister says: Reuters→

June 19, 2019

Asia-Pacific

G7 finance ministers agree on some features of international tax rewrite

July 18, 2019

G7 finance ministers, at their meeting in Chantilly, France on July 17–18, agreed to several aspects of a revised system for taxing multinationals. According to the ministers, the international tax and transfer pricing rules . . .

Europe

French DST passed by Parliament clarifies location of users

July 15, 2019

Pascal Luquet of Grant Thornton Société d’Avocats discusses the details of the final version of the French digital services tax, adopted by French Parliament on July 11 . . .

Asia-Pacific

BEPS multilateral tax treaty to enter into force for Ukraine

August 8, 2019

Ukraine today deposited with the OECD legal documents ratifying . . .

Americas

France seeks to reach digital tax deal with US at August G7 meeting, French minister says: The Local→

July 29, 2019

Europe

Google doesn’t owe French tax on sales to advertisers, court rules

May 23, 2019

Pascal Luquet, Mickaël Duquenne, and Paul Bufort of Grant Thornton Société d’Avocats, Neuilly-Sur-Seine, France, discuss Google’s latest court win in France where the Paris administrative court of appeal confirmed that Google Ireland had no permanent establishment in France and that Google was not taxable in France on Google AdWords sales to French advertisers those years . . .

Belgium

Denmark must adopt EU controlled foreign company tax rules, Commission says

July 30, 2019

The EU Commission on July 25 decided to send a reasoned opinion to Denmark for its failure . . .

Americas

French Senate passes digital service tax despite US threat of potential retaliation, bill likely signed by Macron within two weeks: Liz Alderman / The New York Times→

July 11, 2019

French court reaches surprising conclusions on cost plus transfer pricing method

June 6, 2019

Terence Wilhelm of Cara Avocats, France, discusses a French case, Labs France, where the court addressed the treatment of taxes for purposes of the cost plus transfer pricing method . . .

Americas

France should renegotiate FATCA unless US agrees to concessions aiding dual nationals, parliamentary report says: Gregory Viscusi / Bloomberg→

May 16, 2019

Americas

US formally asks the EU to “ditch” digital tax

October 22, 2018

Alan Rhode, co-founder of Taxmen.eu, discusses a US Senate Finance Committee letter, released last week, challenging the EU digital services tax, as well the latest positions of EU countries on the controversial proposal . . .

Europe

Amazon settles French tax dispute over income allocation for undisclosed sum: Reuters→

February 5, 2018

EU tax on tech firm revenue does not target US companies, Moscovici asserts

April 20, 2018

The EU’s proposed digital services tax is not aimed US tech companies; rather, the interim tax is designed to level the playing field for all businesses wherever located, Pierre Moscovici, EU Commissioner . . .

Europe

France proposes diverted profits tax: EY→

November 26, 2016

See: EY.

Europe

France hits Microsoft with 600 million euro tax bill: L’Express→

September 25, 2017

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

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