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SALE OF SECURITIES BY MEANS OF A VENDOR CREDIT: TAXATION OF THE ENTIRE CAPITAL GAIN IS CONSTITUTIONAL

In a decision of January 14, 2022 (Cons. const. 14-1-2022 n° 2021-962 QPC), the French Constitutional council validates the provisions leading to the immediate taxation of the totality of the capital gain realized at the time of a transfer of securities by means of a vendor credit, even though a part of the transfer price has not yet been paid. In application of the provisions of articles 150-0 A and following of the CGI, the transfer for valuable consideration of the securities of a company generating a taxable capital gain must be considered as the date on which the transfer (...)
In a decision of January 14, 2022 (Cons. const. 14-1-2022 n° 2021-962 QPC), the French Constitutional council validates the provisions leading to the immediate taxation of the totality of the capital gain realized at the time of a transfer of securities by means of a vendor credit, even though a (...)
Tax Law
Illustration of an abuse of rights and taxation of management package gains
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Tax Law
Clarification of the administrative doctrine on the temporary system of neutralisation of free revaluations of assets introduced by the Finance Act for 2021
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Tax Law
Belgian tax authorities and double taxation of French dividends: granting a tax credit under certain conditions
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Tax Law
Non-profit organizations – towards increased control of the sponsorship system
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Tax Law
Decision of the French Council of State on the VAT rate applicable to the services of commercial agents
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Tax Law
Une nouvelle étape est franchie : la CJUE a jugé la taxe de 3% sur les dividendes incompatible avec la directive mère-fille (CJUE, 1e ch., 17 mai 2017, aff. C-365/16, AFEP)
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Tax Law
L’agrément exigé en cas d’apport à une société étrangère n’est pas conforme au droit de l’Union Européenne – CJUE, 1re ch., 8 mars 2017, aff. C-14/16, Euro Park Service
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Tax Law
Plafonnement des frais et commission des produits ISF-PME
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