History
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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 2026NewsConseil 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 busi...
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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 2026NewsCompanies 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 Cour...
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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 2026NewsCommentary 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...