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HTMLThe Conseil D'etat Rules on The Regle Du Butoir
Nicolas Andre, Nicolas Andre, Siamak Mostafavi, Siamak Mostafavi, Alexios Theologitis, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 14, 2016, previously published on January 2016
On December 7, 2015, the Conseil d'Etat (French Supreme Court for most tax matters) decided a case regarding the availability of a French tax credit resulting from foreign withholding taxes suffered by French corporate taxpayers in respect of inbound dividends.

 

HTMLParticipation Exemption Regime Conditions Relaxed For Nonprofit Organizations
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 14, 2016, previously published on January 2016
Among the provisions contained in the 2015 Amending Finance Bill is the adjustment of the Participation Exemption in cases where the French parent company is controlled by a nonprofit organization.

 

HTMLParticipation Exemption Regime Overhaul
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 14, 2016, previously published on January 2016
The 2015 Amending Finance Bill includes various provisions regarding the participation exemption regime (Participation Exemption) and related matters.

 

HTMLConditions of the PEA-PME Regime Relaxed
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 1, 2016
The PEA-PME regime (plan d'épargne en actions de petites et moyennes entreprises, PEA-PME Regime) created by the 2014 Finance Law is an enhanced version of the French stock savings plan regime (PEA), which provides for a specific personal income tax exemption applicable to French individual...

 

HTMLUpdate of The French List of Non-Cooperative Jurisdictions
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 1, 2016
The French Ministry of Economy and Finance published on December 21, 2015 a decree under which the British Virgin Islands and Montserrat have been officially withdrawn from the list of non-cooperative jurisdictions (NCJ List).

 

HTMLCountry-By-Country Reporting Implementation
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 2016
As announced by the French Ministry of Finance few weeks ago, and in accordance with Action 13 of the OECD BEPS Project, Article 121 of the 2016 Finance Bill implements the country-by-country filing requirement.

 

HTMLAutomatic Exchange of Information by French Financial Institutions
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 2016
Article 44 of the 2015 Amending Finance Bill includes several proposals to bring the filing requirements imposed upon French financial institutions in line with EU Directive 2014/107/EU (dated December 9, 2014, and amending Directive 2011/16/EU as regards mandatory automatic exchange of information...

 

HTMLAmendment Of The Wealth Tax Incentive For SME Investments
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 2016
Article 24 of the 2015 Amending Finance Law also amends the French wealth tax (impôt de solidarité sur la fortune, ISF) reduction applicable to certain qualifying investments into SMEs (ISF-PME Regime).

 

HTMLDividend Distributions within French Tax Groupings Now Only 99 Percent Tax Exempt
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 2016
As announced in our December 2015 French Tax Update, in a late parliamentary session on November 30, 2015, the French Government proposed, as part of the 2015 Amending Bill, new provisions to bring the FTC in line with the September 2, 2015 Steria judgment (please see our October 2015 French Tax...

 

HTMLExceptional Depreciation Of Investment By Businesses In SMES
Nicolas Andre, Siamak Mostafavi, Alexios Theologitis; Jones Day;
Legal Alert/Article
January 13, 2016, previously published on January 2016
Article 81 of the 2015 Amending Finance Bill adjusts for the second time the exceptional depreciation for investment in innovative small and medium-sized enterprises (SMEs), in order for this regime to comply with the EU rules on State aid following the authorization by the European Commission...

 


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