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Closure of a Sole Permanent Establishment in France: No Carryback of the Final Loss

Published on : 03/11/2026 03 November Nov 11 2026 16h44 16 44

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Conseil d’Etat, October 23, 2026, No. 509327, Irem SpA. A foreign company that closes its sole permanent establishment in France undergoes a total cessation of business for purposes of Article 220 quinquies of the French Tax Code, eve...

Payroll Tax and the Parent-Subsidiary Directive: The French Supreme Administrative Court Refers a Question to the CJEU

Published on : 15/09/2026 15 September Sep 09 2026 15h18 15 18

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Companies should not wait for the ruling to act By a decision of 7 July 2026, the Conseil d’Etat (France’s supreme administrative court) referred a novel question to the Court of Justice of the European Union (CJEU): is the French taxe sur les...

Debt waivers with a “better fortune” clawback clause: France’s top administrative court clarifies the tax treatment of the resulting income for the lending company

Published on : 29/07/2026 29 July Jul 07 2026 17h31 17 31

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Commentary on Conseil d'État (joint 9th and 10th chambers), 7 July 2026, No. 506015, Sté Sparflex A “better fortune” clawback clause is, by design, meant to revive the waived receivable once the debtor's financial position improves — bringing w...