Once a tax haven for interest expenses, France has recently experienced a significant tax audit activity in this area. Frédéric Laureau, Partner at EY Law in Paris, outlines what could become the new legislation
Annabelle Bailleul and Philippe Juilhard of CMS Bureau Francis Lefebvre discuss the changes introduced by the New UK/France Tax Treaty
Fabrice Rué and Gregory Tulquois of Cariddi Mee Rué, correspondents at the French Bar with DLA Piper Rudnick Gray Cary US LLP, explain the impact of the new tax treaty on the relocation of executives to France
Cliona Murphy, Tax Director, Deloitte & Touche LLP, discusses the impact of the introduction of SDLT on reconstructions and the effective creation of two separate stamp tax regimes
Nigel Doran, partner, and Andrew Loan, solicitor, in the corporate tax group at Macfarlanes, consider the Ramsay principle post-BMBF/SPI and look forward to the outcome of Campbell v IRC
Alan Dolton, Editor of Tolley's Tax Cases and Tolley's VAT Cases surveys some of the leading direct tax decisions reached in 2004. The indirect tax round-up will be published in a forthcoming issue
Philip Martin once again provides us with his very personal opinions. In this article he looks at the Revenue's 'amnesia' as regards challenges under EC Law
Aidan O'Carroll, National Head of Tax, Ernst & Young, considers what the Pre-Budget Report can tell us about future corporate tax trends
Continuing our series of basic, informative articles, Bradley Phillips and Matthew Desborough-Hurst, both of Herbert Smith, cover mergers and acquisitions