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France Tax News

Treaty between Belgium and France: regular participation in commodity exchange held to be permanent establishment

7 October 2008
OECD released 2008 Model Tax Convention

7 October 2008
Discussion draft on New Art. 7 of OECD Model – details

30 August 2008
Treaty between France and Netherlands – French Administrative Court of Appeal finds withholding taxes applied to Dutch pension funds contrary to treaty non-discrimination clause and EU free movement of capital

11 August 2008
OECD Council approves 2008 Model Tax Convention

11 August 2008
Treaty between France and Switzerland – French Supreme Administrative Court holds Swiss resident taxable in France on payments for services performed in France but paid via UK company

11 August 2008
Preliminary ruling requested from ECJ on interpretation of Merger Directive in connection with scheme to avoid Netherlands property transfer tax

11 August 2008
Guidelines on group taxation issued

11 August 2008
Treaty between France and United Kingdom – details

11 August 2008
2008 treaty between France and United Kingdom signed

27 July 2008
Bill on Economic Modernization

27 July 2008
Comments on draft contents of 2008 update to Model Tax Convention published

27 July 2008
ECJ: Netherlands refund regime for investment funds incompatible with EC free movement of capital

21 June 2008
ECJ: Decision by reasoned order in UK CFC and foreign dividend test case

21 June 2008
European Commission takes steps against Bulgaria, Portugal, Romania and Spain concerning taxation of dividends

21 June 2008
European Commission closes infringement procedure against Luxembourg concerning taxation of dividends

21 June 2008
ECJ: Non-deductibility of foreign PE losses in Germany compatible with EC freedom of establishment

21 June 2008
ECJ: Advocate General finds Belgian rules on inclusion of dividends in taxable base followed by 95% deduction insofar as parent company makes profits incompatible with Parent-Subsidiary Directive – details

21 June 2008
Preliminary ruling requested from ECJ regarding compatibility of Belgian tax treatment of foreign dividends with EC free movement of capital

21 June 2008
Draft of 2008 Model Tax Convention – Proposed changes to Commentary to Art. 12 (definition of royalties)

21 June 2008
Protocol to treaty between Qatar and France ratified

14 May 2008
Accession Convention to Arbitration Convention will enter into force for France

14 May 2008
ECJ: 5% add-back of tax credits for withholding tax at source abroad compatible with Parent-Subsidiary Directive

14 May 2008
Advance ruling on whether foreign company entitled to lower rate of CGT on sale of shares in Indian company

14 May 2008
European Commission refers Netherlands to ECJ for not exempting dividends paid to companies established in certain EFTA countries from withholding tax

14 May 2008
French Law ratifying Accession Convention to EC Arbitration Convention published

16 March 2008
ECJ: Advocate General finds German rules on taxation of cross-border dividends under old imputation system compatible with EC law

16 March 2008
Bill to terminate treaty with France adopted by Danish parliament

16 March 2008
European Commission takes steps against Belgium for failure to adopt implementing measures of Merger Directive

16 March 2008
ECJ: Advocate General finds 5% add-back of tax credits for withholding tax abroad compatible with Parent-Subsidiary Directive – details

16 March 2008
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