The Commission also considers that the French legislation contravenes the provisions guaranteeing the free movement of persons (Articles 39 and 43 of the EC Treaty and Article 7 of Regulation (EEC) No 1612/1968) because it means that people who live abroad but remain subject to French income tax by virtue of tax agreements concluded by France may not benefit from the reduction.

The agreements follow the model of the OECD, which means that, in most cases, the income from salaried work (and also freelance work) is only subject to the taxes of either the country in which the work is carried out or the country of residence.

Home State Taxation (where groups of companies would be able to compute the taxable base for all their EU operations according to the tax code of their particular Home State);

The Commission proposal provides for the following: with respect to cultural workers: a system for spreading such workers' incomes over several tax years in applying income taxes; with respect to cultural foundations: appropriate tax exemption for cultural foundations approved by Member States; with respect to patronage: appropriate tax deductions for gifts and bequests to approved cultural bodies or institutions, and tax deductions applicable to patronage where a cash gift or bequest is made to an approved body or person in a Member State other than that in which the patron is resident; with respect to succession duty: the system whereby succession duty can be settled through the surrender of works of art approved by the competent autho ...[+++]rities; with respect to the private architectural heritage: an abatement from the valuee of buildings forming part of that heritage which are subject to "cultural servitudes" arising either from legislation relating to listed buildings or from the fact that they are open to the public, where that value serves as a basis for calculating such taxes as land tax, transfer dduty, annual wealth tax and succession duty; and the deduction from the taxable incomes of the taxpayers concerned of expenditure inccurred in conserving and maintaining those buildings; with respect to cultural investments: a system which does not impose tax disadvantages on cultural investments, and in particular will eliminatee possible tax obstacles to the development of cinema and television co-productions; with respect to widening the audiance: that the Member States will not discourage demand for cultural goods and services by applying high rates of value added tax or of other taxes (1) COM(85) 194 - 2 - The Commission has chosen to couch its proposal in the form of a Resolution so that the Council and the Ministers responsible for Cultural Affairs meeting within the Council can enter into a definite political commitment which at the same time forms the f ...

The consultation concerns direct taxes such as corporate income taxes, non-resident income taxes, capital gains taxes, withholding taxes, inheritance taxes and gift taxes.

Relations between Member states not covered by bilateral agreement (as at 1 January 1991) Denmark* Greece Greece** Spain Greece* Ireland Greece* Luxembourg Greece Portugal Spain* Ireland Portugal* Luxembourg Portugal Netherlands Portugal Ireland * Treaty under negociation ** Treaty signed but not yet in force Tax relief systems: neutrality of treatment between foreign, source and domestic source dividends where a full or partial credit for corporation tax paid (e.g. under an imputation system see P. 2) is given to domestic source dividend income, the same relief is not granted to foreign-source income (e.g. a french resident may receive ...[+++]the benefit of "avoir fiscal" only on french source dividends, but not on foreign dividend income; subject to treaty provisions.