1 – The issue of taxation of the results achieved in France by French partnerships whose partners are non-resident has, for fifteen years, generated some controversy between the advocates of corporate transparency that people wanted, basically, the non-resident partners are taxed in France if the company did not exist and […]
The State Council reaffirms that the non-resident partners of partnerships are taxed in France because of their participation in society and he said that the OECD model tax treaties do not object. The rules for taxing non-resident partners of partnerships are now described. The State Council reaffirms that the non-resident […]
Section 24 allows a French resident to charge the tax due from it in France a tax credit equal to the French tax on U.S. source taxable wages in the United States even if they do have not actually been imposed. CE 29 juin 2011 n° 320263, 3e et 8e […]
The European Commission has, knowingly, introduced in 2007 a case against the only Portugal. Indeed, the case of France is very different. If there is unequal treatment in terms of real estate gains, it is in France, to the detriment of residents : n’acquittent non-resident taxpayers or the CGS or […]
To know how a person will be imposed in France, you must determine whether she/ he is French domiciled from a tax viewpoint. 1 Definition of domicile A person is considered, subject to an international convention, as having his fiscal domicile in France when one of the following criteria in met: – The […]