Main topics :

  • New rules for group tax consolidation perimeters – horizontal tax groups
  • Restrictions on parent company regime
  • Office tax no longer deductible
  • Buyback of own shares
  • Capital gains tax changes affecting non residents
  • Allowable interest rates on shareholder loans
  • Penalties for inadequate transfer pricing documentation for large groups
  • Tax treaty changes
  • Tax audits
  • Nominative Social Declaration (DSN)