As previously reported, on 4 September 2008, Advocate General (AG) Juliane Kokott of the European Court of Justice (ECJ) gave her opinion in the case of Société Papillon v. Ministère du budget, des comptes publics et de la fonction publique (C-418/07). Details of the opinion are summarized below. (a) Facts. French parent company held indirectly through a Dutch company more than 95% of the shares in several French subsidiaries. The French parent company filed a consolidated tax return, including the French subsidiaries that were owned indirectly for 95%, through the Dutch company. The tax administration rejected the application of the...