A decision of a Court of Appeal has ruled that a UK dormant company may not be considered as a UK tax resident for the application of the UK-France tax treaty.
In the case at hand, the French tax department evidenced that the company involved was registered as a dormant company with the UK tax administration, it did not have to file any income return nor have any obligations as regards accountancy or tax. In these circumstances, the Court of Appeal ruled that the French Tax administration was right to consider that this company may not be a UK tax resident company as regards the UK-France tax treaty and may not benefit from it.
CAA NANCY, 2ème chambre, 05/06/2025, 23NC00039
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#UK-France #Tax treaty #dormant company
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