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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 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...
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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 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...
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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 2026 17h31 17 31
News
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...
Read more
Read all news
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