France-Luxembourg Tax Treaty: the final countdown!
The Luxembourg Government Council met on Friday, November 16, 2018 under the chairmanship of Prime Minister Xavier Bettel. Among other topics, the Council has agreed with the draft law approving the Tax Treaty between the Government of Luxembourg and the Government of the French Republic. This new Treaty significantly impacts the real estate sector. It […]
Market rates on shareholder loans: impossible proof?
In a ruling dating from January 18th 2018 (1), the Paris Administrative Court confirmed the administration’s reconsideration of the deductibility of interest in majority shareholder loans granted during an LBO. This decision confirms the administration’s strict position in which it systematically requires a preliminary and hard loan offer from a bank to justify that the […]
Compensation tax: new indications on sectoring, staff allocation and prorata
Three new rulings on April 19th 2018* of the Nantes Administrative Court of Appeal shed new light on compensation tax issues, notably on (i) sectoring justifications, (ii) presumption of transversal activities for managers, and (iii) dividend tax as calculated in the liability report. Sectoring and justifications In the first ruling (Nantes ACA, April 19 2018, […]
Arsene advises Ardian Growth in the sale of its minority stake in Piz’Wich to Frostkrone
Arsene advises Ardian in the sale of its minority stake in Piz’Wich to Frostkrone Arsene advised Ardian, an international leader in private investment, as it performed the sale of its minority stake in Piz’Wich, a major player in the to-go snacking industry. Ardian Growth sold its stake to Frostkrone, a European leader in frozen hors […]
Arsene unveils its 6th Real Estate Tax Barometer: 2018 marks a new context
French law office Arsene, dedicated exclusively to tax issues, has released results of its 6th Real Estate Tax Barometer: –63% of respondents have a positive opinion of President Macron’s tax measures. However, only 31% of respondents are satisfied with real estate measures. –Less than half (45%) of respondents were subject to tax inspection in 2017, […]