France:
Paris Team Authors Article About Definition Of Abuse Of Right And Guarantee Against Changes In Tax Doctrine
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Paris senior counsel
Noël Chahid-Nouraï and partner
Laurent Olléon, formerly members of the tax chambers of
Conseil d'État, France's highest administrative
court, authored
an article in the prestigious French tax review Revue de Droit
Fiscal on substance over form in French tax law. They
discussed the impact of the Paris Administrative Court of
Appeal's decision on December 20, 2018, which ruled that the
French tax administration could accuse a taxpayer of committing an
abuse of right by acting in a way approved by the administrative
tax doctrine. Such a stand, which is debated among French tax
specialists, is not indeed easy to reconcile with the case law of
Conseil d'État and raises important issues related to
the definition of abuse of right, the guarantee against tax
doctrine changes and the necessity of legal certainty.
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