A decree dated 3 February 2023 updated the French list of Non-Cooperative States and Territories within the meaning of article 238-0 A of the FTC: the Bahamas and the Turks and Caicos Islands have been added to the previous list (issued by the decree dated 2 March 2022).

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.