Last publications
Transfer tax in case of shares held in a foreign real estate entity
The French tax administration rules on the possible use of a credit for foreign taxes
Publications
Stock options and international assignments
Taxation of the gains derived from stock options in a cross-border context has been a debated question for several years on the international scene. However, France, unlike other European countries, has not yet taken a stand in this area. The French Supreme Administrative Court (“Conseil d’Etat”) has just partly settled the debate in a decision dated March 17, 2010, in accordance with the guidelines developed by the OECD since 2004.
Stock-Options and termination for cause
The French Supreme Court confirmed for the first time, in a decision dated October 21, 2009 (n°08-42.026, Nebon-Carle c/ Sté Acxiom France), that section L. 1331-2 of the French labour code related to prohibited financial sanctions applies to stock-options.
Contaminated land: clean up obligations and easements
Under French law, when a site has been contaminated by the operation of a classified facility (“installation classee”), the local authority (prefet) sets forth clean up obligations in connection with the future use of the site.