Article 209b (finally) compatible with international tax treaties

Sapsiwai/AdobeStock The Conseil d'État has just ruled that Article 209 of the CGI, as drafted by the Finance Act for 2005, is in line with the bilateral tax treaties. This judgment comes more than two decades after the Schneider Electric case-law, which obliged the public authorities to amend the text of Article 209b of the CGI. Article 209b of the General Tax Code (GIC) is part of the arsenal of international tax avoidance measures of the Frenc…