Non-residents in France receiving all or substantially all of their income, can benefit from the tax shield and the cap of the ISF.
administration give the benefit of tax shield and cap the TFR for non-residents considered tax resident in France under Article 4 B, b or c of CGI since that they perceive France in all or almost all their income and should therefore Schumacker decision (ECJ Case 14-2-1995. 279/93), be treated as residents.
"People who receive most of their professional income from an activity performed in France (...) or receive from France the bulk of their unearned income, including Heritage (.. .) are tax resident in France, "reads the official newsletter of the taxes of 11 January, accessed by AFP. "As a result, the persons concerned, which correspond to non-residents Schumacker, are eligible the right to return (tax shield, ie) (...), and specific cap of the ISF, "it added.
France, which had received a reasoned opinion from the European Commission asking amend its legislation on this point, inconsistent with the principles of free movement of persons and workers will not be brought before the ECJ in this respect.
A follow
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