New French tax laws permit sister companies to consolidate, increase penalties for incomplete transfer pricing documentation

France’s 2015 Finance Act and the Rectificative Finance Act for 2014 have entered into force, reports CMS Bureau Francis Lefebvre in a January 9 tax alert.

Among the law changes are new rules permitting sister companies to consolidate for tax purposes, a reduction in the real estate capital gains tax rate for nonresidents, new limits on the participation exception for dividends, increased penalties for failure to provide transfer pricing documentation, and a new procedure to eliminate withholding tax on deemed dividends from transfer pricing adjustments, the firm writes.

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