CMS Annual Tax Conference 2025

1. Recent trends in international fiscal policy & update on French tax treaties

Adapting to a Shifting Global Tax Landscape

The international tax environment is undergoing rapid transformation, with increased regulatory scrutiny, evolving treaty negotiations, and a push for greater transparency. This session will explore key developments in global tax policy and provide insights into France’s latest approach to tax treaties, helping businesses stay ahead of new challenges and opportunities.

2. Looking for the beneficial owner

Securing Treaty Benefits Amid Heightened Compliance Pressure

Tax administrations are challenging withholding tax exemptions and reductions under tax treaties and EU directives, applying the beneficial owner test with increasing scrutiny. A panel of CMS tax experts will examine the legal grounds for these challenges and discuss strategies to strengthen compliance and safeguard treaty benefits.

3. Tax transposition of the EU directive on corporate reorganisations

From Policy to Practice: How EU Countries Are Implementing the Directive

The EU directive introduces significant changes to corporate reorganisation rules, reshaping tax frameworks across member states. This session will analyse how different jurisdictions, including France’s 2025 Finance Bill, are incorporating these legal changes into their tax systems—highlighting key risks, opportunities, and compliance considerations for multinational companies.

4. Transfer pricing on financial transactions

Staying Ahead of Tax Audits in Intra-Group Financing

Tax authorities are intensifying audits of intercompany financial transactions, from intra-group loans to cash pooling. With increasing scrutiny on substance and arm’s length pricing, this session will provide practical guidance on defending transfer pricing policies, managing risks, and ensuring compliance in an evolving regulatory environment.

We look forward to welcoming you in March 2025!