FRANCE ISSUES BLACKLIST OF 17 ABUSIVE TAX SCHEMES
19 April 2015
The French tax administration refers to several examples of perceived abuses that were discovered during tax audits.
The French tax authorities target the following transactions:
- “management package” schemes
- dividend stripping
- relocation of profits following a restructuring
- commission payments to low-taxed related parties
- fictitious lowering of the wealth tax base computation
- undisclosed foreign wages
- foreign commission payments to French directors
- fictitious relocation of workforce
- treaty shopping
- shareholder participation changes eliminating dividend withholding taxes
- double interest deductions
- avoidance of the territoriality threshold for donation duties
- VAT avoidance by deferring service payments
- abuse of the “plan d’épargne en actions” by use of cross participations
- abuse of the “plan d’épargne en actions” by use of conduit companies
- non-disclosure of the French VAT threshold of EUR 100.000 sales / year
- fictitious lowering of the wealth tax cap
The list is not limitative and will be further completed based on the outcome of future audits.
If your company is involved in this type of transactions, we recommend to voluntary file a rectification return with the French tax authorities in order to avoid the announced penalties.
More information: http://www.economie.gouv.fr/dgfip/carte-des-pratiques-et-montages-abusifs
Contact
Should you require further information or assistance with said rectification, please do not hesitate to contact one of our team members of the BDO Competence Centre International Corporate Tax: