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France Publishes Order on Requests for Pre-Restructuring Ruling on Non-Application of Anti-Abuse Rule

11 July 2018

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Approved Changes

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France

France has published the Order of 25 June 2018 on submitting requests for a pre-restructuring ruling from the tax authority confirming the non-application of part III of Article 210-0 A of the Tax Code. Part III includes the new anti-abuse rule introduced by the Amending Finance Law for 2017 to provide that the benefit of tax deferral in respect of mergers and divisions will not be available if the main purpose, or one of the main purposes, of a transaction is the evasion or avoidance of tax. The anti-abuse rule applies from 1 January 2018.