A Threat to Foreign Holding Companies Owned by French Residents
For several years, the French tax administration has intensified its scrutiny of holding companies owned by French tax residents.
Gathering evidence in the workplace: a frequently overlooked criminal risk
Swiss companies are regularly confronted with foreign requests for evidence without always understanding the potential criminal consequences.
France: what will taxation look like in 2026?
With no compromise reached within the allotted time frame, budget discussions will resume in January, bringing with them a host of uncertainties.
Company director and contract with oneself: Yes, but…
Case law has ultimately identified a number of important principles. A recent decision of the Federal Supreme Court helps illustrate the issues and shed light on the solutions adopted.
Inheritance and banking information: what access do heirs have?
The protection of banking information does not end with the account holder: Heirs must be patient and prove their entitlement to access It.
Red card in case of dormant cash
The Paris Court of Appeal closes the door on eligibility for the ‘Dutreil’ scheme.
AMLA and criminal liability of companies in cases of money laundering
Since its introduction into Swiss law on 1 October 2003, corporate criminal liability has given rise to little published case law, making its application uncertain.
International double taxation: behind the scenes of a discreet but decisive reversal
In a recent decision, the French tax judge has secured cross-border transfers by recognising the right to full refund of foreign tax.
France: the appeal of universal taxation
The idea of introducing broader taxation on taxpayers leaving France is a recurring theme in tax news.
Is there implicit subordination of shareholder loans made to a company in difficulty?
The Swiss Supreme Court has just handed down an interesting decision on the controversial question of whether and under what conditions loans from persons closely related to a company in difficulty are subordinated.
Founding member of the
