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
Chris Llallemand, of Akerman Limited, reports on two CIoT Commerce & Industry Group meetings with Inland Revenue International, held on 22 September and 13 October 2004
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
Nigel Eastaway, Senior Tax Consultant, Chiltern plc, reviews Extracting Profit from the Family Company by Roger Jones; Published by LexisNexis; 28pp; price £25
Alan Kennedy, Senior Manager, KPMG's Tax Investigations practice, discusses the guidance on finality for taxpayers issued by the Revenue following the Veltema case
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