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WTS in France

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FIDAL
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Home Locations France
   
 

Since January 2021 WTS Global expanded its presence in France significantly by winning FIDAL as a new member firm. FIDAL offers the full scope of tax services.

FIDAL is the biggest French tax law firm in France with representation in more than 90 offices across the country. 

Working alongside our clients for almost 100 years, we know all the economic and institutional players and understand their issues.
Proud of our history but clearly focused on the future, we are constantly adapting our services to anticipate our clients’ needs and assist them in their development.
Our team of 1400 professionals advise domestic and international clients across all areas of business law.

Rich with 17 nationalities, our talents are based in 90 offices across France.

Being originally established as a tax firm, tax constitutes an important pillar of our business. Our professionals provide services in all core areas of tax, including international tax advisory, local taxes, R&D tax credit, tax technology, global mobility services etc. We also offer  every kind of tax litigation since most of our tax professionals are trained lawyers. Tax is strongly embedded in our DNA and we have many years of experience working with independent consulting firms to provide our clients with a one-stop service on a global basis.

We stand for independence, confidentiality, and agility and act as genuine business partners for our clients.

The new cooperation between Fidal and WTS Global  and its member firms reinforces our commitment to offer seamless full service cross-border tax advice to our clients.

Awards

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Laurent Leclercq
Managing Director/Partner
France
http://www.Fidal.com
+ 33 1 55 68 16 42
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Local News

This article summarizes the 2025 Finance bill, enhancing the global minimum tax regime with OECD instructions on deferred taxes and "transparent" entities, effective for financial years ending after Dec 31, 2024

France: Amendments made by the Finance bill for 2025 to the Pillar Two mechanism
Read more

The purpose of this note is to provide a didactic presentation of the reporting obligations, particularly aimed at the many "small groups" subject to Pillar Two regulations which are still at the beginning of their project and the French subsidiaries of foreign groups subject to this regulation.

France: Pillar Two - Overview of the Reporting Obligations for Constituent Entities Established in France
Read more

News on tax developments affecting the international Financial Services industry.

WTS Global Financial Services Newsletter #1/2025 is now available
Read more

Foreign entities owning real estate in France could face a 3% annual tax unless they meet specific disclosure requirements. Recent court rulings highlight key conditions for tax exemptions.

France: Tax Alert: 3% French Real Estate Annual Tax
Read more

In France, losses incurred by a company in a given fiscal year can be carried forward to offset profits in subsequent years, without time limit.

France: Tax losses - their utilization, the impact of restructuring operations and recent case law
Read more

France has introduced the principle of gradually making the use of electronic invoicing compulsory from 2019 (law no. 2019-1479).

France: e-Invoicing in France - New schedule
Read more

A couple of months ago, the e-invoicing and e-reporting reform was still foreseen to progressively enter into force as from 1 July 2024, with a timetable extending until 1 January 2026.

France: Latest key French VAT updates
Read more

The French tax administration tried to increase the scope of French withholding tax by increasing the beneficial ownership requirements in cases where French banks acquire shares temporally from foreign shareholders.

France: French WHT on dividends - Banking institutions and beneficial ownership
Read more

For FYs opened as from 1 January, 2023, groups have the possibility to set up a captive reinsurance company in France whose purpose is to exclusively reinsure the own risks of the group.

France: New regime for the set-up of a captive reinsurance company
Read more

This article examines the Paris Administrative Court of Appeal's ruling on corporate income tax and residency, reshaping how tax treaties are interpreted.

France: Proof that the non-resident company is subject to corporate income tax by reason of its status or activity
Read more

On 22 December 2022, France and Switzerland reached an agreement on the taxation of home office income.

France & Switzerland: Agreement on the taxation of home office income
Read more

During the past 18 months, the French Supreme Administrative Court (Conseil d’Etat) has rendered several decisions requalifying capital gains realised by managers of companies

France: Management package: back to reality?
Read more

New rulings regarding local research tax credits paving the way for consistently deducing the local research tax credits and/or similar subsidies from any R&D cost-plus services provided by eligible French companies

France: Research Tax Credit and Subsidies Synergies with Transfer Pricing
Read more

The VAT regime applicable to distance sales has been amended as of 1 July 2021.

Spontaneous regularisation of French VAT on distance sales by foreign operators
Read more

In its decision, the French supreme tax court (Conseil d’Etat) had to decide whether, in the presence of intermediary companies, the treaty with the state of residence of the beneficial owner should be applied

Double tax treaties: application of the double tax treaties and beneficial ownership CE, 20 May 2022, n° 444451 Sté Planet
Read more

Under the parent-subsidiary regime, dividends received by a parent company are exempt from corporate income tax (CIT)

French Supreme Tax Court validates the possibility of charging foreign tax credits on the share of costs and expenses on dividends
Read more

In principle, every employee recruited from abroad to take up a position in France is affiliat­ed to the compulsory French social security schemes for basic and supplementary retirement pension insurance.

France: French pension “impatriate” regime: exemption from affiliation and from payment of pension contributions
Read more

Recent case law regarding intercompany cash pool interest rates in a decision involving the SAP Group. 

France: The SAP Case - The Difficulty for Tax Courts when Handling Negative Interest Rates
Read more

Reminder of the French tax regime applicable to interest

Intra-group interest in France – improvements for taxpayers
Read more

Over the past few years, responsibility for taxes has been in the process of being transferred from French customs to the French tax authorities

France: The Goods and Services Tax Code – (A way to clarify the applicable rules!)
Read more

The notions of “main entrepreneur” and “routine entity” are often used, as it is the routine entity’s margin which will be set, with the entrepreneur receiving the residual profit/loss.

The RKS case: shades of nuance in TP by the French Supreme Administrative Court
Read more

Article 21 of the French 2022 Finance Act retroactively adjusts certain tax rules to re-establish the tax neutrality which, until the legal modification introduced by the PACTE Law of 22 May 2019, had benefitted shareholders and unitholders in demergers of UCIs aimed at segregating their illiquid assets.

France: Tax measures on gains from the sale of digital assets
Read more

France has recently announced that it will join other Member States that have gone ahead of EU regulations and imposed electronic invoicing.

France: Changes in sight
Read more

The draft of French Budget Bill for 2022 proposes to facilitate the election for VAT taxation of banking and financial in order to make French Funds Managers more competitive as from 1 January 2022.

France: Amendment to the option for VAT for banking and financial services
Read more

An important decision on the characterization of a permanent establishment in France has been rendered by the French Supreme Administrative Court (Conseil d’Etat) in the Conversant International Ltd case (CE, 11 December 2020, n° 420174).

France: Continuation and end of the Conversant International Ltd case - Permanent establishment in the digital field
Read more

France has an attractive regime to incentivize foreign talents to take up residence in France: the impatriate regime.

France: Impatriate regime – Paris Administrative Court of Appeal’s decision of 16 March 2021
Read more

Clarifications have recently been provided, through decrees and an order, on the conditions for accessing and consulting data contained in the registers of trusts and “fiducies” (French-style trusts) kept by the French General Directorate of Public Finances (Direction Générale des Finances Publiques, DGFiP).

France: Clarifications on the procedures for accessing information contained in registers of trusts and fiducies
Read more

Clarifications have recently been provided, through decrees and an order, on the conditions for accessing and consulting data contained in the registers of trusts and “fiducies” (French-style trusts) kept by the French General Directorate of Public Finances (Direction Générale des Finances Publiques, DGFiP).

France: Impatriate regime – Exemption from affiliation and from payment of pension contributions
Read more

In three decisions dated 13 July 2021 (nos. 428 506, 435452 and 437 498) and a ruling of 17 November 2021 (no. 439 609), the Conseil d’Etat (French Supreme Administrative Court) has clarified the tax treatment of gains from incentive plans that offer managers an equity interest in the companies they work for  (“management packages”).

France: Recent reconsideration of the tax treatment of management packages: Implications in an international context
Read more

Clarifications have recently been provided, through decrees and an order, on the conditions for accessing and consulting data contained in the registers of trusts and “fiducies” (French-style trusts) kept by the French General Directorate of Public Finances (Direction Générale des Finances Publiques, DGFiP).

France: Update on the 2022 Finance Act
Read more

The French Tax Authorities (“FTA”) have just published comments clarifying their position with respect to recent case law governing the fate of flows between the branches (branch or head office) of a single legal entity, which are also members of a VAT group in the State in which they are established.

Operations between head office and branches: the French tax authorities comment on EU cases Skandia and Dansk bank
Read more

Companies ensuring the operation in France within the meaning of Articles L. 5124-1 and L. 5124-2 of the French Public Health Code of one or more pharmaceutical specialties reimbursable or covered by health insurance, are liable for the contribution relating to the amount M (“Contribution M”) when the sum of the tax-free turnover achieved by these companies is greater than an amount M determined by law.

France: Pharmaceutical companies - Challenging the 2019 Contribution M
Read more

European counterparts distinguish the French customs authorities by the diversity of their tasks and missions, as well as by the fragmentation of their organisation. To improve the efficiency and productivity of its administrations, the French government has decided to reorganise the missions of tax, customs and fraud administrations.

Customs administration – French cultural exception?
Read more

The French Tax Administration has grown bolder and has deployed new, ambitious approaches both proposing a different Transfer Pricing method and providing an economic analysis to support the profit allocation.

The Engie Case: an ambitious new approach by the French Tax Administration
Read more

France announced an ambitious reform that was to enter into force from 1 January 2023 but a couple of days ago it was postponed until July 2024.

France: First flavour of the planned ambitious e-invoicing and e-reporting reform
Read more

The French research tax credit (“CIR”) has undergone several changes recently, as a result of new French Supreme Court case law, the 2021 Finance Act and the updating of tax authorities guidelines.

France: An overview of recent news regarding the research tax credit (CIR)
Read more

Today, the EU reform of the rules on cross-bor-der distance selling is undoubtedly moving in the same direction with the introduction of the one-stop shop. Against this trend, it is worth noting the reform regarding the payment of import VAT in France as from January 2022.

France: Facilitating the reporting obligations of foreign operators: two steps forward, one step back?
Read more

The French Supreme Court has just refined its definition of permanent establishment in France for VAT and corporate income tax (CIT) purposes (CE, 11 December 2020, No. 420174, Min. c/ Société Conversant International Ltd).

The French Supreme Court refers to the international definitions of permanent establishment
Read more

In France, after half a century, the status quo of the tax regime regarding intangible assets is changed. Our French colleagues outline some of the principles behind the newly established “Nexus” approach.

France: Self-financing through intangible assets or how to generate significant tax savings
Read more

Our summary of R&D Incentives provides guidance where such incentives are provided, and who in WTS Global can support you to gain from these incentives for your business or individually the most.

R&D tax allowance in Europe
Read more

In accordance with European regulations, the scope of the e-invoicing obligation will be extended to all domestic transactions between companies starting 1 January 2023. The 2020 French Finance Bill (Article 153) sets four objectives for the introduction of this obligation.

E-Invoicing & E-Reporting obligations in France
Read more

On 21 February 2021, the French tax authorities (FTA) published their related comments, providing useful interpretive guidance on the French Treaty as well as other treaties based on the MLI model.

The new French-Luxembourg tax treaty: comments from the French tax authorities
Read more

The French tax authorities published their comments on the effects of the United Kingdom’s withdrawal from the European Union on the tax benefits granted to individuals and legal entities in respect of investments made in the EU or the European Economic Area.

Consequences of the Brexit on direct tax in France
Read more

The Amending Finance Bill for 2021, intended to finance the various accompanying measures related to the health crisis, was presented on 2 June to the Council of Ministers and is now before the Parliament.
Among the key measures, eagerly anticipated by companies, the temporary removal of the limit on the carry-back of losses.

France: Amending Finance Bill for 2021
Read more

The French Supreme VAT Court provides taxpayers with an extended timeframe for the reporting of input VAT.

France: Timing of input VAT deduction – favourable court ruling
Read more

In France, to deduct the full amount of intergroup interests, a French company must prove that the paid interests are not excessive. Our French colleagues outline some of the principles behind this regulation.

France: Proof of the interest rate applied between related companies
Read more

Major changes postponed to 1 July 2021

France: VAT Cash OptimisationVAT reform for e-commerce
Read more

A tax focused perspective on the current French lockdown.

French Newsflash: Covid measures
Read more

The so-called “quick fixes” measures, provided by the Directive 2018/1910/EU and by the French finance Bill for 2020, effective since January 1st 2020, were recently commented by the French tax authorities (hereafter ‘FTA’) in their official guidelines (BOFIP update on October 14th, 2020).

French VAT Alert: Comments on Quick Fixes
Read more

VAT Alert by Villemot WTS

First French Application of the Skandia ECJ caselaw
Read more

Our French colleagues explain what needs to be considered from a transfer pricing perspective in these times of COVID-19, especially with regard to documentation requirements, the use of benchmarking studies and the deductibility of interest expenses.

France: Impact of the crisis on transfer prices
Read more

An overview on VAT crash optimisation.

France: VAT Cash Optimisation
Read more

Article 13 of the French finance bill for 2020 introduced a new tax domiciliation criterion for executives of large French companies

France: Tax domicile in France of the corporate executives of French major companies
Read more

Obligations of online marketplaces have been increased recently in France, with the aim of improving VAT collection and the new DST (digital service tax) collection.

France: New tax obligations for online marketplaces
Read more

Mandatory electronic invoicing between the government and its suppliers

Evolution of electronic invoicing in France
Read more

The measures proposed will be included in the Finance Bill for 2020 and unveiled at the end of September 2019

France: VAT liability for online marketplaces and other measures to fight VAT fraud
Read more

France has been one of the last OECD member countries adopting a pay-as-you-earn (PAYE) system

France: New income tax collection system
Read more

The French Minister of Economy and Finance has introduced a draft law creating a tax on digital services

France introduces its own tax on digital services
Read more
Show more

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