The active holding company, a tax ‘open sesame’ for business owners, has been defined by the legislator without putting an end to practical difficulties and diverging interpretations between practitioners and the tax authorities.
Based on a Cour de cassation ruling denying a holding company ‘active’ status — and the related wealth tax exemption — the authors analyse the persistent difficulty of defining an active holding company and the burden of proof.
Read the original excerpt in French →
Would you like the full article, or to discuss this topic with the author? Contact the firm.
Request the article