Technical papers

French income tax accounts for most of the disputes we handle for individuals and company directors.

Articles in this section deal in particular with social security contributions on SASUs taxed under income tax, the treatment of management packages, withholding tax on dividends, intragroup royalties and the voluntary disclosure window announced for 2027.

Income tax

Matters

Gift Tax International tax Wealth Income tax Positions France-US Tax Desk

Unpaid SASU President: France's Cour de cassation Contradicts Bercy

Income tax - Published on October 9, 2026

The ministerial answer of 2 June 2026 assumes unpaid presidents are not affiliated. On 4 June, the Cour de cassation stated otherwise. What it changes.

SASU Income Tax and CSG: Authorities Contradicted by Own Guidance

Income tax - Published on September 28, 2026

Published guidance, the ministerial answer of 2 June 2026 and the genesis of the 2024 reform: three incompatible readings of the SASU president's profit, and three grounds for the reassessed director.

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

Income tax - Published on September 21, 2026

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.

France Announces a 2027 Voluntary Disclosure Window for Undeclared Assets

Income tax - Published on September 21, 2026

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.

Management packages: capital gain or salary? The tax regime

Income tax - Published on September 7, 2026

Is a management package gain a capital gain or salary? The article 163 bis H regime, the tax deferral trap and international mobility, explained.

Matters

Gift Tax International tax Wealth Income tax Positions France-US Tax Desk