Resumen de France : Court of Appeals confirms incompatibility of CFC rules with tax treaties

Pierre-Jean Douvier, Dali Bouzoraa

• On 30 January 2001 the Administrative Court of Appeals of Paris ruled that the application of French CFC legislation is irreconcilable with Article 7(1) of the (old) France-Switzerland tax treaty. In a case note, the authors analyse the implications of the decision against the background of earlier case law.