Court of Appeals confirms incompatibility of CFC rules with tax treaties

Journal
Bouzoraa, M.A.; Douvier, P-J.
France; Switzerland
European Taxation 2001 (Volume 41), No. 5
Format/Price
JournalUSD 45

On 30 January 2001 the Administrative Court of Appeals of Paris ruled that the application of French CFC legislation is irreconcilable with Article 7(1) of the (old) France-Switzerland tax treaty. In a case note, the authors analyse the implications of the decision against the background of earlier case law.