Scope of application, the concept of allocation to an economic activity, the treatment of certain real estate assets, and the risks associated with restructurings undertaken to fall outside the scope of the measure: behind a stated aim of being targeted, the regime raises numerous questions of interpretation and legal certainty.
Julien highlights a central issue: as things stand, the measure leaves several major uncertainties unresolved, which call for a careful reading of the text and its practical effects.
Read the full article on the Journal Spécial des Sociétés website – JSS: https://jss.fr/post/taxe-sur-les-holdings-un-cadre-juridique-encore-fragile
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