To obtain an Advance Tax Decision from the tax authorities, the taxpayer must write a request (the Request) by mail to the Administration of Contribution Directes of which it depends.
The Request for an A.T.D. must describe in detail the taxpayer, its activities and the third parties involved in the transaction.
The Request should mention in detail the operation which is contemplated by the taxpayer.
A detailed analysis of the corporate and tax law should justify the Request of ruling and the motivation of the tax treatment applicable to such operations.
Finally the Request should also certify true and accurate the facts which are mentioned in the Request.
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