Insights

Our lawyers regularly analyse developments in French and international tax law: new legislation, landmark court decisions and their practical consequences for businesses, investors and private clients.

SUMERSON Publications

Our Articles

In-depth notes by our lawyers on recent French and European tax case law, published on this site in English and French.

  1. English · Français

    Article 123 bis of the French Tax Code (FTC) and the Conseil d’État’s “Level One” decision: the difficulties raised by the characterisation of the QPFC

    By Nicolas Duboille & Mathis Rossignol

    A note on the Conseil d’État’s Level One decision of 30 June 2026, which transposes the Axa and Raymond case law on the QPFC to Article 123 bis of the French Tax Code, and the questions it raises under the Parent-Subsidiary Directive, EU freedoms and constitutional principles.

    Read the article: Article 123 bis of the French Tax Code (FTC) and the Conseil d’État’s “Level One” decision: the difficulties raised by the characterisation of the QPFC

International Tax Review

Our Articles in International Tax Review

International Tax Review (ITR) is a leading international publication on tax law and policy, read by in-house tax teams, advisers and tax authorities around the world.

SUMERSON contributes to ITR as a French publisher, writing on French tax developments for an international readership. The articles below were published on internationaltaxreview.com.

See SUMERSON on ITR