Residence under tax treaties and burden of proof

In a decision dated 26 November 2019 (no. 418593), the French Conseil d'Etat says there is no need to adjudicate the case given the full tax rebate pronounced by the Minister during the proceedings. In this case, in which employees were recruited abroad to work in France, the tax authorities

VAT on the « profit margin scheme » for second-hand vehicles

The tax administration waives the right to appeal a judgment in favour of the taxpayer obtained by Frenkel & Associés from the Administrative Court of Besançon (21 May 2019, Nos. 1600456 and 1702138) in a case in which the tax inspectorate claimed that a motor vehicle dealership could not have