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

Withholding tax on dividends: the parent-subsidiary exemption

Income tax - Published on August 31, 2026

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.

Intragroup brand royalties: transfer pricing and the risks

Income tax - Published on August 24, 2026

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

SASU Under Income Tax: The French Government's Flawed Stance

Income tax - Published on June 3, 2026, updated on August 18, 2026

The French Government's reply on SASU social levies ignores Article L. 136-3 CSS and the Paris Court of Appeal ruling.

French Tax Audit Targeting Algorithm: A Practitioner's Framework

Income tax - Published on May 18, 2026, updated on November 2, 2026

Technical mapping of the atypia signals exploited by the DGFiP targeting models, reconstructed from publicly available ministerial orders, CNIL deliberations and parliamentary reports.

Trademark Licensing by Directors in France: A Comprehensive Tax Guide

Income tax - Published on April 20, 2026, updated on October 12, 2026

Comprehensive analysis of the French tax and social treatment of trademark royalties between director-licensor and licensee company.

Matters

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