This newsletter contains information on the following topics:

• Editorial
  Professional secrecy status accorded to information reported to the administration: a very broad topic…
• Transfer Pricing
  - THE OECD consults with practitioners regarding the use of transactional profit methods for transfer pricing.
  - French Tax administration can use independent appraisers
• Companies
  - Assets leased by partnerships - Limitation on the deductibility of depreciation allowance.
  - Compensation for services paid for in a foreign country: Is the application of Article 155 A of the French Tax Code compatible with provisions of tax treaties with Switzerland and the United Kingdom?
  - Research tax credit: Eligibility of the research expenses incurred by a company re-invoiced to another company (Advance Ruling No. 2008/08)
• Tax Audit
  Principle of retroactivity of the softest criminal law / Application to the previous penalty for default of payment of withholding tax.
• Employee Benefit
  New Guidelines Published For Tax Deductions on French Tax- Qualified Awards
• Real Estate Tax
  - Tax penalties and judge’s power to moderate: the 5% fine provided for in Article 1788 A of the French General Tax Code is euro-compatible!
  - Real Estate VAT - Regime applicable to the acquisition of building lands by a professional developer after the reform of urban planning authorisations.