New guideline on recognition of transparency principle for foreign partnerships

Journal
Author
Baranger, S.
Country
France
Published Date
Issue
European Taxation 2007 (Volume 47), No. 8
FormatPDF
EUR
45
| USD
50 (VAT excl.)

On 29 March 2007, the French tax administration issued a Guideline on the application of tax treaties to French-source passive income received via foreign partnerships. This note considers the Guideline by way of a summary of the OECD approach in the situations covered by the Guideline, and descriptions of the traditional French translucency approach, the changes entailed by the Diebold decision and the most important provisions of the Guideline.