OrbitaxGuideline on French CFC rules published – details
|Approved Changes|France
On 16 January 2007, the French tax administration published a lengthy Guideline (4H-1-07) on controlled foreign company (CFC) rules. The Guideline covers (i) the definition of a CFC and a low-tax jurisdiction, (ii) attributed income, (iii) the interaction with tax treaties, (iv) double taxation relief and (v) safe-harbour rules.
Background
The French CFC rul…
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