France Court of Appeal of Paris Issues Decision Clarifying Tax Residence Under DTA With Morocco

The French Court of Appeals of Paris Aug. 29 issued Decision No. 23PA04153, clarifying tax residence under the 1970 DTA with Morocco. The taxpayer, an individual, was assessed social security contributions, additional individual income tax, and the exceptional contribution on high incomes, based on securities capital gains. The French tax authorities found the taxpayer was domiciled for tax purposes in France and not Morocco. The Paris Administrative Court discharged the assessed amounts at issue. On appeal, the the Court of Appeals of Paris found that: 1) the taxpayer didn’t have a permanent home in Morocco under the DTA for the ...