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French Supreme Administrative Court Rules on Interaction of CFC Rules and Tax Treaty with Mauritius

|Treaty Development|France-Mauritius
France-Mauritius

The French Supreme Administrative Court (Conseil d'Etat) issued a decision on 13 March 2025 dismissing an appeal concerning, among other things, the interaction of the French controlled foreign company (CFC) rules and the provisions of the 1980 income and capital tax treaty with Mauritius. The case involved Rubis Energie, a member of a tax-integrated group headed by Rubis, which was the subjec…

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