OrbitaxCompatibility of exclusion of indirect ownership through companies in other EU Member States for French tax consolidation purposes with freedom of establishment referred to ECJ
|Approved Changes|France-EU
The French Administrative Supreme Court gave its decision on 10 July 2007 in the case of Ministry of Finance v. Société Papillon (No 284785). Details of the decision are summarized below.
(a) Background. Arts. 223A to 223Q of the CGI contain a set of rules that allow French companies that are members of a group to file a consolidated tax return (régime d'intégration…
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