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France: St. Barthélemy companies may belong to French tax group

Ruling issued on October 23, 2024, clarifies conditions under which St. Barthélemy companies may belong to French tax group

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December 17, 2024

The French tax authorities on October 23, 2024, issued a ruling clarifying the conditions under which a company based in St. Barthélemy can be part of a French tax consolidation group.

Specifically, companies in St. Barthélemy may only be considered St. Barthélemy residents for tax purposes if they have effective management there for at least five years or are controlled by residents for the same duration; otherwise, they are subject to French corporate income tax and can join a tax consolidation group.

For more information, contact a KPMG tax professional:

Marie-Pierre Hoo | mhoo@kpmgavocats.fr

Patrick Seroin-Joly | pseroinjoly@kpmgadvocats.fr

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