In a ministerial response dated 31 August 2023, the French Minister of the Economy recently commented on the obligation for French tax residents to annually declare their foreign bank accounts, clarifying that the fact that a person holds a shareholding in a foreign company or is its corporate officer is not in itself sufficient to fall within the scope of this reporting obligation.

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.