June 14, 2022

  Are the days of Citizen by Investment over? Is the end near? 28 March 2022, the European Commission issued a recommendation urging states to immediately repeal any existing Citizenship-by-Investment (CBI) schemes and to ensure that strong checks were in place to address the risks posed by Residence-by-Investments (RBI)schemes. It further recommended that member states […]

We have written extensively about French taxation – https://htj.tax/?s=france+tax Tax residence – domiciled fiscal is a criterion for tax liability – a foyer, business activity or centre of economic interest in France. The devolution of a resident’s estate is strictly regulated by law, with some exceptions for foreign nationals. Lifetime gifts are not tax–exempted. Life

  Forced heirship is found in France. Lifetime gifts can be clawed back. It did not prevail over the Californian law in the Jarre case. The EU Succession Regulation provides for determining the applicable tax. Courts in the EU have come to a different conclusion about the applicability of forced heirship under ‘ordre public’ (public

  Today’s reflection…. Action 6 of BEPS introduced the principal purpose test (PPT). It is one of the minimum international tax standards applicable by countries members of the BEPS Inclusive Framework The PPT aims to tackle treaty abuse including treaty shopping  1. Subjective element: Tax administrations need to reasonably conclude, having taken into account all