Septembre 2014
In terms of legal certainty, it seems essential that the notion of a holding company be defined in a clear and precise manner, using criteria and presumptions that can be implemented in a simple and secure manner. The taxpayer must be able to judge before a transaction wether his holding company is a facilitator or wether he sould opt for another method of application of the tax arrangements.
This study is written by Jean-François DESBUQUOIS, associate lawyer, Philippe NEAU-LEDUC, Professor of Law, and Pascal JULIEN SAINT-AMAND, Althémis Paris Notaire.
This study is only available in French.