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.
Overview of the main French-Swiss tax news
The purpose of this study is to provide an overview of current tax developments in Switzerland and France on issues that may be of interest to both jurisdictions.
(Mixed) donation of a property and taxation of the gain
Taxation of property gains is deferred when the property is transferred by donation. A recent ruling by the Swiss Supreme Court clarifies the details.
Churning objectivity: some useful parameters
In private law, churning is not a defined term, and the question of when an asset manager engages in behaviour that constitutes churning depends on several factors.
Focus on the French Finance Act 2025
The new Finance Act contains several measures affecting taxation of individuals.
France: Fines on declaration obligations of trusts and foundations
Failure to comply with the aforementioned reporting obligations may result in a fine of €20,000 per failure to report over a period of four years.
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