15 January 2018

A review of the substantial tax system modifications pertaining to corporate tax restructuring

Following the Euro Park Service rulings (EUJC, March 8 2017, aff. C-14/16 and State Council, June 26 2017, N°369311), lawmakers were required to put an end to the discrimination created by differential treatment of contributions between two French companies that fulfilled merger control conditions, were not subject to preliminary agreements, and contributions made by a French company to a foreign company, subject to a preliminary agreement.

Option Finance N°1445, January 15th 2018