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Philippe Fernandes

Philippe Fernandes is an Associate in Baker McKenzie, Paris office.

The Tax Court of Appeal of Paris judges, in a dispute concerning the statute of limitations for tax collection, that the United States does not have a legal instrument on mutual assistance for tax collection that is “equivalent” to the one provided for by Council Directive 2010/24/EU of 16 March 2010. Such an interpretation of the tax treaty concluded between France and the US could have consequences on other tax regimes, and in particular on French exit tax.