Tax answers with official sources.

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Feedback from the groups below shaped how IFG cites official sources, separates missing facts, and keeps each answer reviewable.01, 02, 03

01Private practice · partners and counsel on cross border matters
02Big Four · tax advisory, transfer pricing, M&A
03Corporate tax · in house groups, treasury, family offices

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Not a loose chatbot reply. IFG keeps the answer, official references, assumptions, points to review and missing facts attached to the same question.

Sources Official references are cited and checked as of the answer date, with the authority level kept visible.
Facts Assumptions and missing facts are separated from the answer, so you know what can still change the analysis.
Review Points to control, unresolved issues and follow-up questions stay together for professional review.

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Votre cabinet Avocats & fiscalistes
Tax research memo

Management fees: audit defence

Question

At what conditions do the management fees paid by the French subsidiary to its parent remain deductible, and how do we make the file audit-proof?

Brief answer

Deduction remains defensible only if the services are real, useful to the French company, and priced at arm's length.

Analysis

Under article 39 of the CGI, these fees are deductible only on three cumulative conditions: real and individualised services, a benefit to the subsidiary's own business, and arm's-length pricing. The classic reassessment route is the abnormal act of management: under BOFiP guidance and the Conseil d'État case law, the burden falls on the materiality of the services and the consistency of the charging key.

Facts to lock

Dated deliverables, invoices, benefit test, transfer-pricing support, decision trail.

IFG
Votre cabinet Avocats & fiscalistes
Client letter

Royalties to Singapore: reducing the tax withheld

Dear Sir or Madam,

You are about to pay brand royalties to your Singapore company. By default, France withholds 25% at source; this rate can be substantially reduced under the France-Singapore tax treaty.

To qualify, before the first payment we must obtain the Singapore tax-residence certificate (forms 5000 and 5003) and show that the company receiving the royalties is the genuine beneficiary. We prepare these documents and align the filing with your payment schedule.

Without these documents at the time of payment, the 25% withholding applies automatically and has to be reclaimed afterwards, so it pays to have everything ready upfront.

This advice covers the French tax withheld on these royalties, based on the information you provided and the rules in force today. We remain at your disposal.

Yours sincerely,
Your firm
IFG

Official sources, in every jurisdiction.

Official sources retrieved through native provider web search and ranked by legal authority. Coverage shows mapped official-source domains by jurisdiction.

FAQ
Is IFG a legal opinion?

No. IFG provides a sourced tax answer for practitioner review, not signed advice. Counsel still owns the judgment, the client relationship and any opinion letter. IFG is designed to give you verifiable material before you decide your final position.

How do I verify the sources are in force?

Each answer cites the official references used and keeps the checked date visible. IFG separates statutes, treaty text, official guidance and institutional material. If a reference cannot be verified, the answer should say so instead of hiding the uncertainty.

What happens when the law is silent or contradictory?

IFG does not force certainty. The answer flags the conflict, separates competing positions, cites the authority available and marks the point for review. Unverified or contradictory points are not treated as final conclusions.

Confidentiality. What happens to the facts I submit?

Question facts are handled under IFG's confidentiality undertaking. Queries are encrypted in transit and at rest, and are never used to train models. Redacted submissions are recommended for tests. Bespoke deployments define retention, access control and tenant configuration contractually.

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