CSG and CRDS by HMRC
Getting confused about french CSG and CRDS….so many contradictions
Is a UK tax payer entitled to :
- Claim foreign tax credit relief : Clearly a confusion between article 2 and 24 of the treaty. The first defines what French Tax is (and that includes CSG and CRDS). The second does not (for the purpose of french tax credit relief in the UK…does not make sense at all.
Also, the French courts ruled many times that CSG and CRDS are indeed taxes. shouldn't be then considered that the have to be credited against UK tax ? I mean 24, 2, c does/t work. they can't limit in 24 the list of french taxes once defined in art 2.
- or, at the very least, deduct those "taxes" from his taxable income. paragraph 1 says UK tax on french income should be calculated on the same income on which the French tax is calculated….meanwhile the French impot is calculated on Gross-(CSG+CRDS)
Anyone has experience of that?
After and prior to 2010 when the New UK/France Treaty entered into force?
Article 2,1,b reads :
n the case of France, all taxes imposed on behalf of the State or of its local authorities irrespective of the manner in which they are levied on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amount of wages or salaries paid by enterprises, as well as taxes on capital appreciation; those taxes are in particular:
(i) the income tax (l'impôt sur le revenu);
(ii) the corporation tax (l'impôt sur les sociétés);
(iii) the social contribution on corporation tax (la contribution sociale sur l’impôt sur les sociétés);
(iv) the tax on salaries (la taxe sur les salaires);
(v) the “contributions sociales généralisées”;
(vi) the “contributions pour le remboursement de la dette sociale”;
2. This Convention shall also apply to any identical or substantially similar taxes which are imposed by either Contracting State after the date of signature of this Convention in addition to, or in place of, the taxes referred to in paragraph 1. The competent authorities of the Contracting States shall notify each other of any substantial changes which have been made in their respective taxation laws.
Article 24, 2, c
(c) the taxes referred to in clauses (i) to (iv) of subparagraph (b) of paragraph 1 of Article 2 and, in respect of the taxes mentioned in those clauses, in paragraph 2 of Article 2, shall be considered French tax.
- Late Registration for VAT 460 13
- How do you find shareholders of a Cyprus Company ? 138 11
- What is the amount of dividends received as a shareholder that requires registration for self assessment? 48 1
- EIS/SEIS 122 1
- Amortisation of Goodwill 248 1
- You know its over 150 2
- Cocaine anyone? 417 7
- TaxCalc Accounts production 384 5
- Depression - HMRC penalties case won because of this illness. 386 12
- Solicitors now, Accountants next 645 10
- How come if you claim benefits you are not entitled to you either have to pay a 50% penalty or are sent to court and either fined or sent to prison (sometimes suspended) and end up with a criminal record. 515 10
- ACCA - still making me laugh 535 4
- Valuing my fast-growing internet business for transfer of goodwill on incorporation 69 1
- Personal pension 384 9
- Legal Aid Agency claims and VAT 212 1
- How much of your work is admin? 1,191 11
- Accountancy practices - are you closed over Christmas or do you let your staff take it off? 890 27
- Petrol expenses for self-employed 116 3
- Is Co House "losing" Abbreviated Accounts? 1,502 22
- Holding Company - Ltd or PLC? 307 4
- Hive up 479
- Accounting referance change & deficient accounts. 443
- corporate hierarchy 423
- Advice - 261
- Anyone had HMRC refusing to act on EPS database glitch? 216
- WWOOFers 212
- Co. limited by Guarantee now closed 198
- Art Gallery - Splitting a property between business and personal use 190
- Mutual Trading - Exempt CT Income - Do I need clearance? 169
- Tax liabilities in USA for warehoused products 165