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    France: Tax losses - their utilization, the impact of restructuring operations and recent case law
    2024-04-09

    In France, losses incurred by a company in a given fiscal year can be carried forward to offset profits in subsequent years, without time limit. The annual offset against future profits is limited to a maximum of €1 million, plus 50% of the portion of profit exceeding this threshold. Any unused balance is carried forward to the following year. It is also possible to opt to carry back losses against the previous year's profits, up to a maximum of €1 million.

    Filed under:
    European Union, France, Insolvency & Restructuring, Litigation, Tax, WTS Global, Court of Justice of the European Union
    Location:
    European Union, France
    Firm:
    WTS Global
    Decision of the Austrian Financial Court regarding Transfer Pricing
    2022-12-23

    On June 2, 2022, the Austrian Financial Court ruled on the arm's length nature of a) the liability commission in context with a shareholder loan, b) the Transfer Price of products and c) the crediting of trade receivables (GZ. RV/7102082/2009).

    Filed under:
    Austria, Insolvency & Restructuring, Litigation, WTS Global, Transfer pricing
    Authors:
    Martin Hummer
    Location:
    Austria
    Firm:
    WTS Global
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