Alert / Newsletter
Corporate and transactional taxation
The 14 March 2023

Beneficial owner, beneficial owner and tax treaty

If the administration questions the beneficial owner, do not forget to take advantage of the applicable tax treaty.

Our corporate and transactional tax team comments on a decision of the Paris Court of Appeal of 7 December 2022 which dismisses the protective provisions of the Parent-File Directive and the Franco-Luxembourg Convention on the grounds that the beneficiary of the amounts is only an apparent beneficiary.