Referral to the CJEU regarding the taxation of foreign accounts
The Court of Justice of the European Union has been asked to rule on a preliminary question concerning Articles 755 of the General Tax Code (CGI) and L.23 C of the Financial Procedures Code (LPF), which provide for the taxation of assets held, in particular, in foreign accounts when the taxpayer is unable to provide evidence of the origin and manner of acquisition of such assets.
The question concerns whether the exemption from the statute of limitations provided for in these provisions constitutes an infringement of the free movement of capital, and the scope of such an infringement.