Technical papers

Income tax

SASU Under Income Tax: CSG Assessment Error, a Public Policy Ground

Three discharges, an assessment rule reported in the tables, a ground the court raises of its own motion: what the case law changes for the reassessed SASU director.
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France Announces a 2027 Voluntary Disclosure Window for Undeclared Assets

France's Prime Minister has announced a voluntary disclosure window for 2027. Ten years after the STDR, should taxpayers wait or act now? Our analysis.
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Management packages: capital gain or salary? The tax regime

Is a management package gain a capital gain or salary? The article 163 bis H regime, the tax deferral trap and international mobility, explained.
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Withholding tax on dividends: the parent-subsidiary exemption

Paying dividends to a European parent free of withholding tax: the conditions of the 119 ter regime and the domestic conditions now challenged by case law.
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Intragroup brand royalties: transfer pricing and the risks

An umbrella brand royalty justifies at best a symbolic remuneration. Indirect profit transfer and abnormal act of management: how to secure your policy.
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