A new argument against the withholding tax of article 119 bis of the CGI
In an important case that gave rise to a favorable decision by the Administrative Court of Bordeaux on January 26, 2021 (n° 1903677), which the administration did not appeal, was at stake an alleged liberality granted by the French subsidiary of a Chinese group to a sister company in the
2021
Apr
Conference “The undeclared permanent establishment: from presumption to repression” of 13 and 15 April 2021
In April 2021, Marc Pelletier chairs a conference organised by the IACF's Control and Litigation Commission on the subject of undeclared permanent establishment.
2021
Mar
The constitutional tax law column 2020
In March 2021, Marc Pelletier published the constitutional tax law column devoted to the year 2020.
2020
Nov
New address
As of 16 November 2020, Frenkel & Associés is transferring its office to 89 avenue Kléber - 75116 Paris.
2020
Oct
Frenkel & Associés once again confirmed as “unavoidable” by the guide Décideurs – Stratégies financières et fiscales
In its October 2020 edition, the guide "Décideurs - Stratégies financières et fiscales" confirms the classification of Frenkel & Associés as a "must" in the "Major Tax Litigations" and "Tax litigation and Tax audits assistance" categories.
2020
Sep
“DAC6: The Countdown Continues”, conference on September 16, 2020
In September 2020, Alain Frenkel chairs a conference organized by the Control and Litigation Commission of IACF and devoted to DAC 6 Directive (mandatory declaration of cross-border arrangements that are potentially "aggressive" from a tax perspective).
2020
Jul
2020
Jun
An interview with the Firm’s partners on the new definition of abuse of rights
An interview of the firm's partners in Décideurs Gestion d'Actifs et Patrimoine June 2020 [in French]: The new definition of abuse of rights completes a repressive arsenal
2020
Mar
The constitutional tax law column 2019
In March 2020, Marc Pelletier published the constitutional tax law column devoted to the year 2019
2020
Mar
40 % penalty for bad faith and statute of limitations
By a decision of the Paris Administrative Court of Appeal of March 11, 2020, the Firm obtains a discharge from the 40% penalty for bad faith applied to a reassessment resulting from the reinstatement in the taxable income of the applicant company of the amount of the balance of a