Perspectives

The dispute over France's 3% tax has shifted from property value to transparency over the holders. State of play and impact of the 2027 reform.

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

Analysis of the French tax regime for manual gifts: disclosure as the taxable event and its territorial consequences for non-residents relocating to France.

How to articulate the Italian D.Lgs. 139/2024 reform, the 1990 France-Italy convention and the German § 21 ErbStG credit to optimise cross-border gifts from Italy.

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