Communications from the firm

Sorry, this entry is only available in French.A l'occasion d’une affaire en cours devant une cour administrative d’appel, le Cabinet présente un moyen nouveau relatif à la compétence des services pour l’établissement de la retenue à la source de l’article 119 bis du CGI. Dans le cadre de la généralisation

Sorry, this entry is only available in French.Dans une affaire initiée par le Cabinet, la cour administrative d’appel de Paris vient de juger que des redevances de marque assises sur le chiffre d’affaire et le bénéfice d’une société constituent des revenus professionnels soumis aux contributions sociales sur les revenus d’activité.

in translation

A French company that was a subsidiary of a foreign company was inactive, but a bank account opened in its name had been used to help one of its foreign sister companies, which the tax authorities qualified as a gift subject to the withholding tax under Article 119 bis of

The tax authorities were considering taxing a Swiss resident who held a large property in France through intermediary companies, one of which was French. Frenkel & Associés argued that, although it could not be disputed that the French company had a preponderance of real estate assets, the Swiss resident escaped

In the context of a reassesment procedure concerning registration duties on the transfer of company shares, the tax authorities had served the procedural documents on the transferee company but not on the transferor (whose registered office was in Hong Kong). Frenkel & Associés, relying on the case law of the

In April 2023, Marc Pelletier will be co-chairing a conference organised by the IACF's Control and Litigation Committee on the abuse of rights. At this essentially practice-oriented event, Marc Pelletier will discuss a largely unknown subject: abuse of rights in the case law of the Court of Justice of the

In an important case which Frenkel & Associés is about to refer to the Administrative Court of Bordeaux, an alleged liberality granted by a French company, subsidiary of a Chinese group, to a Hong Kong sister company is at stake, which the administration claims to subject to the withholding tax

Frenkel & Associés has raised an unprecedented issue concerning the territorial jurisdiction of the tax auditors of the departmental public finance services as defined in article 4 of the amended decree of 16 June 2009. These provisions allow for territorial jurisdiction to be extended in certain situations "when justified by

In November 2022, the guide Décideurs – Stratégies financières et fiscales distinguishes Alain Frenkel as a "must" in the Wealth taxation category - regularization and litigation.