France and United States: Tax treaty – scope of the mutual assistance clause

In brief

The Tax Court of Appeal of Paris judges, in a dispute concerning the statute of limitations for tax collection, that the United States does not have a legal instrument on mutual assistance for tax collection that is “equivalent” to the one provided for by Council Directive 2010/24/EU of 16 March 2010. Such an interpretation of the tax treaty concluded between France and the US could have consequences on other tax regimes, and in particular on French exit tax.

In more detailThe case at hand concerned a US citizen taxpayer, who was subject to additional income tax and social […]

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