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By João RODRIGUES Liliana PIEDADE, Tax Lawyers
A French court has recently upheld the taxation of a hollow Luxembourg company. A tax court in Delhi has declined to strip treaty benefits from a credible one. Read together, the two rulings return the substance debate to its central question: whether the entity’s account of its own role can withstand the facts. The line they draw is factual rather than doctrinal, and far more demanding than any checklist.
The company that was run from France
Coupole Finance (Case No 25NT01793, Administrative Court of Appeal of Nantes, 24 March 2026) has...
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