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The regime of articles L 23 C of the tax procedure code and 755 of the general tax code threatened by a decision of the CJEU

Marc Pelletier comments, in the Revue de Droit Fiscal and La Semaine Juridique – Entreprise et Affaires, on an important decision of the Court of Justice of the European Union declaring the Spanish system to fight against the concealment of assets abroad contrary to the free movement of capital. This solution could call into question the analogous French regime, codified in Articles L 23 C of the tax procedure code and 755 of the general tax code.

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