Latest publications

The « Dutreil » pact in an international context: a precautionary measure to effectively reduce the French tax cost of a company transfer
The fact that a company or its shareholders are located outside France sometimes makes people forget that French tax law imposes duties on gratuitous transfers in many cases, even though the deceased (or donor) is domiciled abroad. The surprise will be bitter for the heirs of an unprepared succession.

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.