Traduction de «Prior to tax » (Anglais → Français) :

On the contrary, the fact that the payment of tax due by EDF to the state as revenue collector, including by the regularisation and discharge of the tax that had not been collected prior to Act No 97-1026, was constantly taken into account for the purposes of examining and setting the remuneration to the state as shareholder tends to indicate that the disputed tax exemption was adopted by the state acting as a public authority and ...[+++]not as an investor.

However, none of the documents prior to or contemporaneous with the supposed decision not to levy tax, that were submitted by France or EDF in support of their comments on the decision to extend the formal investigation procedure, made any direct or indirect mention of the supposed decision to invest, with its implications, benefits or costs, or of the corresponding decision to increase the amount of contributed capital by not levying tax.

1. Until 12 months have elapsed from the date of the declaration for its final importation, personal property which has been imported exempt from tax may not be lent, given as security, hired out or transferred, whether for a consideration or free of charge, without prior notification to the competent authorities.

The exemption, remission or deferral of prior-stage cumulative indirect taxes (5) on goods or services used in the production of exported products in excess of the exemption, remission or deferral of like prior-stage cumulative indirect taxes on goods or services used in the production of like products when sold for domestic consumption; provided, however, that prior-stage cumulative indirect taxes may be exempted, remitted or deferred on exported products even when not exempted, remitted or deferred on like products when sold for domestic consumption, if the prior-stage cumulative indirect taxes are levied on inputs that are consumed i ...[+++]n the production of the exported product (making normal allowance for waste) (6).

The inter-action could be limited to the mere notification of a transfer pricing adjustment (which could speed up dispute resolution), be extended to prior consultation between tax administrations before a transfer pricing adjustment was made final (which could again speed up subsequent dispute resolution or avoid any subsequent resolution ever becoming necessary) or use of a system of prior agreement (whereby a tax administration would have to agree to provide a corresponding adjustment to eliminate any double tax before the first adjustment was made final) to prevent a dispute from coming into ...[+++] existence in the first place.

The Commission will consider the findings of the expert group and will use them as a basis for discussion with the tax authorities of the Member States, in accordance with the established policy of prior consultation on tax issues.