French Administrative Supreme Court decision on the concept of beneficial owner

Written by Jean-Florent Mandelbaum, Victor Camatta and Ronan Vallerie

Published in Le Fiscal by Doctrine

In a particularly comprehensive decision, the French Administrative Supreme Court provides certain answers, on both procedural and substantive aspects, relating to the concept of beneficial owner. However, the way it avoids addressing the question of the compatibility of Article 119 ter of the French General Tax Code and the Parent-Subsidiary Directive with freedom of establishment is rather unsatisfactory. Read more