The Resource Re BNP Paribas : No 351702

Re BNP Paribas : No 351702

Re BNP Paribas : No 351702
Re BNP Paribas : No 351702
Judgment by the Conseil d'Etat, France, judgment date 12 June 2014. BNP was a French company which had a wholly owned subsidiary in Canada, with which France had a double taxation convention. Under French tax law, the net profits of an enterprise operated in France were taxable in France. Under the convention, the sale of a substantial shareholding in a company was taxable only in the country where that company was resident. BNP claimed depreciation of the value of its shares in the Canadian company as a deduction in calculating its taxable profits. The French tax authorities disallowed the deduction and imposed supplemental tax and contributions. BNP appealed unsuccessfully to the appropriate tribunal and then to the Administrative Appeals Court, which denied BNP's petition. BNP then appealed to the Conseil d'Etat against the decision of the Administrative Appeals Court
Citation source
In: International tax law reports. - London. - Vol. 16 (2014),
Language note
  • English
  • French
Baker, P
  • case law
  • tax treaty
  • capital assets
  • depreciation
  • non-resident company
Re BNP Paribas : No 351702

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