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The Cour de Cassation delivers a major judgment regarding active holding companies of groups

08 July 2019 | Newsletters

After many years of uncertainty and misunderstanding by taxpayers and legal professionals, the question as to whether a single minority shareholding by a group’s active holding company is sufficient to deprive it of its active nature has been decided.

The Cour de Cassation (Supreme Court of the judicial order) delivered a major judgment last 19 June definitively invalidating the position of the [French] Tax Administration, which considered that a group’s active holding company loses this capacity if it does not actively manage all of its subsidiaries.

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