{"id":72645,"plugin_id":"plugin_asdk_app_6a3ed75340f481918077b38ed53f59d8","kind":"skill","collection_source":"plugin_package","comparison_source":null,"observed_at":"2026-10-31T00:35:31.895Z","digest":"b1769a07bfedd3c91359715f9ead724099171b2b453939d5e77bf4f806224995","against":null,"payload":{"description":"Research tax law with IFG official sources: find the right text, read it at the date of the tax event, check the quotes and cite its official link. Use when the user asks about the tax law of France (overseas territories included), Luxembourg, Switzerland (federal and cantonal), Belgium, Germany, Monaco, Andorra, Italy, the United Kingdom, the United States (federal and selected states) or an EU member state, a tax treaty, EU tax law, OECD guidance or the UN Model: a rule, rate, threshold, deadline, exemption, ruling or case, even when IFG is not named.","included_files":[],"name":"tax-research","skill_md_contents":"---\nname: tax-research\ndescription: Research tax law with IFG official sources: find the right text, read it at the date of the tax event, check the quotes and cite its official link. Use when the user asks about the tax law of France (overseas territories included), Luxembourg, Switzerland (federal and cantonal), Belgium, Germany, Monaco, Andorra, Italy, the United Kingdom, the United States (federal and selected states) or an EU member state, a tax treaty, EU tax law, OECD guidance or the UN Model: a rule, rate, threshold, deadline, exemption, ruling or case, even when IFG is not named.\n---\n\n# Tax research with IFG\n\nIFG serves official tax texts (laws, codes, treaties, administrative doctrine, rulings, case law, forms) with their official source, the version applicable at a given date and a clickable citation. You reason; IFG delivers the sealed text.\n\n## Method\n\n0. **Connect IFG first.** If the IFG tools (`search_authority`, `get_authority`, `changes_since`, `browse_instrument`, `check_sources`) are not available in this conversation, IFG is installed but not connected yet. Do not answer the tax question from memory. Reply, in the user's language, with one short sentence: open Settings, then Plugins, then IFG, connect the IFG account (7-day free trial), and ask the question again.\n1. **Never answer tax law from memory.** Every rule you rely on comes from a text returned by IFG in this conversation.\n2. **Find the authority** with `search_authority`:\n   - `query` is a reference (`CGI 119 bis`, `LIR 56bis`, `AStG 7`, `treaty/CH-FR-1966/11`, `ECLI:FR:CE…`, `BOI-RPPM-RCM-30-30-20-20`) or an official title, never a question or a sentence.\n   - `jurisdiction` is required for a free query: `FR`, `LU`, `CH`, `BE`, `DE`, `MC`, `AD`, `IT`, `GB`, `NL`, `ES`, `HU`, `SI`, `HR`, `CZ`, `SK`, `EE`, `LV`, `LT`, `MT`, `BG`, `GR`, `AT`, `SE`, `DK`, `FI`, `IE`, `PT`, `RO`, `US`, `PL`, `CY`, `treaty`, `EU`, `OECD`, `UN` (United Nations: UN Model Tax Convention). Other EU countries opened one by one: `NL` the Netherlands, `ES` Spain, `HU` Hungary, `SI` Slovenia, `HR` Croatia, `CZ` Czechia, `SK` Slovakia, `EE` Estonia, `LV` Latvia, `LT` Lithuania, `MT` Malta, `BG` Bulgaria, `GR` Greece, `AT` Austria, `SE` Sweden, `DK` Denmark, `FI` Finland, `IE` Ireland, `PT` Portugal, `RO` Romania, `PL` Poland, `CY` Cyprus.\n   - A country code also finds its subdivisions: the 26 Swiss cantons (`CH-GE`, `CH-VD`, `CH-ZH`…), the German Länder (`DE-BY`…), the Belgian regions (Flanders, Wallonia, Brussels) and the Andorran parishes; a subdivision code (`CH-GE`, `BE-VLG`, `AD-07`) is also accepted.\n   - French overseas: `PF` French Polynesia, `NC` New Caledonia, `WF` Wallis and Futuna, `PM` Saint Pierre and Miquelon, `BL` Saint Barthélemy, `MF` Saint Martin have their own tax codes, not `FR`. `RE` Réunion, `GP` Guadeloupe, `MQ` Martinique, `GF` French Guiana, `YT` Mayotte are overseas departments: French national tax law applies there and is served under `FR` (search with jurisdiction `FR`); their own code holds only local texts (octroi de mer, local deliberations).\n   - Use `kinds` to stay in one layer when needed (`code`, `statute`, `treaty`, `doctrine`, `rulings`, `case_law`, `forms_procedure`, `legislative_history`, `eu_law`, `official_data`).\n3. **Read the text** with `get_authority(id, date?)`:\n   - Pass `date` = the date of the tax event (payment, year end, death, transfer). Without it, IFG reads today's law.\n   - Check `applicability.status` (`applicable`, `applicable_with_amendments`, `not_yet_in_force`, `repealed`, `publication_only`, `unresolved`) and `future_effects` before concluding. In `future_effects`, only the next effect comes in full; the next four give their date, change, source and act (`future_effects_total` counts them all when there are more): pass `include_versions` to read them all with their wording. Each effect's source is the official piece that dates it (the amending act or its application clause). `applicable_with_amendments` means the served wording applies but is not the whole rule: an official act IFG holds changes it without a consolidated text from the publisher, or a non-codified act replaces one of its amounts for the tax year of the facts; read it with the acts in `applicability.readWith` (their warnings come first) and never conclude on the served text alone.\n   - Use `passage` with a short literal phrase to read only the relevant paragraphs of a long text.\n   - A warning `publication_date_after_today` means the publisher dates the piece after today (an announced publication, such as a ministerial answer awaiting its Journal officiel): keep that date, and never cite the piece as published before it.\n   - Links are dated by the `date` you pass: a decision, a constitutional ruling or a citing provision dated after it never appears in `constitutional_review`, `leading_decisions` or `cited_by_decisions`; it comes in `constitutional_review_later` and `cited_by_decisions_later` (three at most, with `cited_by_decisions_later_total`), which describe later law, not the law of the facts. A decision's summary is served once.\n   - A warning `leading_decisions` lists the leading decisions on the provision, strongest first (decisions their publisher marks as important whose official summary names it, Court of Justice judgments that cite it, and decisions whose operative part or stated principle of law names it, such as an Italian Constitutional Court ruling declaring it unconstitutional), each with its official summary when published: they may refine or restrict the literal reading; read them before concluding.\n   - `cited_by_provisions` (with the warning `cross_tax_references`) lists provisions of the country's other laws that refer to this one, each with the sentence that refers to it (for example GewStG § 8 Nr. 5 adding back, for the trade tax, dividends exempt under KStG § 8b): read them before concluding on the total tax burden.\n   - Practitioner links, in every answer: a treaty article gives `oecd_model`, the OECD Model article it follows with its edition (read that article and its commentary; `oecd_model_status: not_read` is a gap, not proof that the article departs from the Model); a law article gives `legislative_history`, `forms` and `official_data`, the preparatory works, forms and official data that cite it (`later: true` when dated after the facts: use the form or data of the year of the facts); a decision gives `procedural_history`: the decision it judges (by court and date when IFG does not hold it), the decisions that judge it and the Advocate General's or public rapporteur's opinion (`conclusions`). Check whether a later decision judges the one you cite before relying on it; `procedural_history_status: not_read` means IFG has not read the procedure yet, never that nothing followed.\n   - For a treaty article dated only by the treaty's entry into force (`applicability.reason: treaty_application_unread`, with `entryIntoForce`), IFG has not read the treaty's own application clause: read its entry-into-force article (usually one of the last articles) before concluding for facts before the 1 January given in `condition`; a treaty usually applies from the 1 January, or the tax period, following its entry into force.\n   - For a treaty whose effect depends on the tax (`applicability.reason: tax_effect_scope_ambiguous`), read it again with `tax_context` taken from `availableSelectors`, or copy a call from `nextCalls`. When that tax is dated by the start of the tax period (\"taxable periods beginning on or after\"), also pass `tax_context.periodStart`, the first day of the taxpayer's tax period (financial year, tax year) the facts belong to: IFG then serves the wording that governs that period (`applicability.reason` `tax_period_started_after`, or `tax_period_started_before` with the previous wording, applicable until the period closes). Never guess that date: ask for it. A clause the Multilateral Instrument created (no earlier wording exists) read on a period that started before its date answers `not_yet_in_force` with reason `tax_period_started_before`: the treaty applied without that clause for that period. A `tax_context.scope` that is not in `availableSelectors` returns the warning `tax_context_scope_not_offered`: pick a listed value.\n4. **Write the answer in IFG's form, then call `check_sources`** (see \"Answer form\" below): each text named inside the sentence that relies on it, that name linked to its official version (`citation.url`); the official sources at the end, with their version and status at the date of the facts; then `check_sources(date, sources)` re-reads each text at that date, checks the words you quoted and shows the IFG control card under the answer. Never cite a text IFG did not return.\n5. **Treat gaps honestly**: `official_proof_required`, `identifier_unresolved`, `no_hit_for_this_query` and `time_budget` are typed gaps, not proof that a text does not exist. Retry `time_budget`; say plainly when a source is missing.\n6. If `textVerification` is `ocr_unverified`, say that the text is an unchecked OCR transcription and point to the official PDF.\n7. For monitoring, `changes_since(jurisdiction, since)` lists legal changes (created, amended, repealed, new decisions and rulings) from a date, including announced future effects. For France, the default feed (no `kinds`, no `workId`) over at most 92 days comes by importance, each effect carrying `importance`: `legislation` (tax codes, acts, ordinances, decrees, treaties) first, then `administrative_doctrine`, `leading_decision`, `regulation` (arrêtés), decisions by court level, and `information` (administration pages, forms, data) last; report the first ranks first and follow `nextCursor` for the rest. An Advocate General's opinion comes as `new_opinion`: it is not a decision and decides nothing; never cite it as the Court's ruling. A change whose effective date is not proven carries `noLaterThan` (in force at the latest on that day) instead of `effectiveFrom`; in `get_authority`, such a version has `from` null and `publisherVersion` with `dateBasis: no_later_than`: never treat it as an effective date. A doctrine, ruling, form, administration page, data or legislative-history item is dated by its publication (`publicationDate` with `dateBasis: publication`, no `effectiveFrom`): it is a publication, never a legal effect on that day (an announcement of next year's ceiling is not a change in force).\n8. **Case analysis.** Before concluding on a case, list the conditions the texts set that decide it (beneficial owner, holding threshold and period, tax status of each party, nature of the assets, anti-abuse rules, tax years concerned) and check each against the facts given: a condition the facts do not establish is never assumed met; say what is missing and what changes if it differs. Present the case as: facts and assumptions; the rules, each condition with its text named and linked as in the Answer form; uncertainties (leading decisions that refine the reading, missing facts); reassessment risks (requalification, abuse of law, beneficial ownership, another tax affected); the documents to obtain.\n9. **Source dossier.** When the user wants a verifiable set of sources rather than an answer, use the IFG prompt `dossier_sources` if your client lists it, or follow the same route with the four tools: (1) the dated facts (date of the operation, tax concerned, States involved, start of the tax period; list a missing fact as \"to ask\", never assume it); (2) each national provision, found by its reference and read with `date` = the date of the facts, with its status, dates and conditions and the texts that complete it or derogate from it; (3) when two States are involved, the treaty article read at the same date with `tax_context` for the tax concerned (the values the answer offers) and, when that tax is dated by the start of the tax period, `tax_context.periodStart`, with the effects of the multilateral convention, its anti-abuse clause and the reservations; (4) the administrative doctrine in force on that date that the answer links to the provision, opened at the same date, and the doctrine published later, flagged as such; (5) the decisions the answer links to the provision (`include_links` for the full list), the constitutional censures or annulments and Court of Justice judgments it flags, and the important decisions issued after the doctrine cited; (6) the EU directive transposed and its proven links, if any; (7) for each decision, its procedure (the decision it judges, those that judge it, the opinion), and for each article the OECD Model article, preparatory works, forms of the year of the facts and official data the answer links to it. Present one row per piece: the piece (its `citation.markdown`), its nature (law, treaty, doctrine, decision, legislative history), its version or date, its status on the date of the facts with any condition left to check, its reliability in plain words (verified official text; unchecked OCR transcription; translation without official value; advocate general's opinion or Official Journal notice, not a decision; consolidated version without official value; discrepancy found by IFG's control), and what the piece says, quoted word for word. Then list the open conditions and the facts to ask, IFG's typed gaps as gaps (never as proof that a text does not exist), and any possible divergence between a doctrine and a later decision, without concluding. Never put a technical field name in the dossier; the professional draws the conclusion.\n\n## Answer form\n\nIFG sends every assistant this form, word for word, in its server instructions:\n\n> Answer as a tax professional in the user's language: name each text in the sentence that relies on it as a link to its citation.url, never a string of links after a sentence; quote decisive words; end with \"Official sources (IFG), law at <date>\", each text with version and status, then what remains to check; no field names; cite only texts IFG returned. Then call check_sources(date, sources: ids read, words quoted): IFG checks each quote in the official text at that date and shows the sources; correct a quote it reports missing, else add nothing.\n\nIn practice:\n- Name each text the way a tax professional writes it, inside the sentence that relies on it: \"le I de l'article 209 B du CGI\", \"le BOFiP (BOI-IS-BASE-60-10-20-10, § 120)\", \"l'arrêt du Conseil d'État du 13 mars 2025 (n° 488080)\", \"article 67 LIFD\", \"§ 8b KStG\". That name is the link to its official version: `[le I de l'article 209 B du CGI](citation.url)`. Never a parenthesis of links after each sentence, never a bare URL, never a footnote number.\n- Quote the decisive words in quotation marks, exactly as IFG served them.\n- End with the heading \"Official sources (IFG), law at <date>\", in the user's language (\"Sources officielles (IFG), droit au 30 juin 2025\"), with the date of the facts (today when none is given): one line per text the answer relies on, its reference linked to `citation.url`, then its version and status at that date in plain words, as `citation.text` and `applicability` give them (\"applicable, version in force since 1 January 2015\", \"repealed since…\", \"not yet in force\", \"published on…\").\n- Then what remains to check, under a short heading in the user's language (\"Points à vérifier\"): facts not established, open conditions, later decisions or texts, IFG's typed gaps (never as proof that a text does not exist). Leave it out when nothing remains.\n- Then call `check_sources` once: `date` (the date of the facts), `sources` (one entry per text, in the order cited: `id` as IFG returned it, `passage` the decisive words you quoted, `label` the name you used). IFG re-reads each text at that date, checks that the words you quoted are in the official text (a quote with an ellipsis is checked fragment by fragment; a quote under three words, or a text whose transcription is not reviewed, is not checked), and shows the IFG control card under your answer (Claude on the web, desktop and mobile; ChatGPT): status and version in plain words, each quote found (with its extract) or not found in the wording at that date, what IFG links to the text (guidance, case law, upcoming amendments), the full text one click away, the citation to copy. The check says only that the words are in that text at that date, never that the quote supports your reasoning. If it reports a quote as not found, re-read the text (`get_authority` with `passage`) and correct the quote or the version cited in one sentence; otherwise add nothing. A client that shows no card still gets the check in the tool result.\n- Never show IFG's field names or codes (`applicability.status`, `applicable_with_amendments`, `tax_context`…): say what they mean.\n\nExample, French question, facts on 30 June 2025 (texts as IFG served them):\n\n> Le [I de l'article 209 B du CGI](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000029355796/2015-01-01) vise la personne morale établie en France et passible de l'impôt sur les sociétés qui détient « directement ou indirectement plus de 50 % des actions, parts, droits financiers ou droits de vote » d'une entité établie hors de France et soumise à un régime fiscal privilégié au sens de l'article 238 A : les bénéfices ou revenus positifs de cette entité sont alors imposables à l'impôt sur les sociétés. …\n>\n> **Sources officielles (IFG), droit au 30 juin 2025**\n> - [CGI, art. 209 B](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000029355796/2015-01-01) : applicable, version en vigueur depuis le 1er janvier 2015 (loi n° 2014-891 du 8 août 2014, art. 20).\n>\n> **Points à vérifier**\n> - Le régime fiscal privilégié de l'entité (article 238 A) : les faits ne l'établissent pas.\n\n## Scope\n\nFrance and its overseas territories, Luxembourg, Switzerland and its cantons, Belgium and its regions, Germany and its Länder, Monaco, Andorra and its parishes, Italy, the UK, the Netherlands, Spain, Hungary, Slovenia, Croatia, Czechia, Slovakia, Estonia, Latvia, Lithuania, Malta, Bulgaria, Greece, Austria, Sweden, Denmark, Finland, Ireland, Portugal, Romania, Poland and Cyprus, their tax treaties, the EU, the OECD and the UN Model; more countries are added one by one. Coverage and known gaps are declared country by country; IFG is a documentary infrastructure — the professional remains responsible for the legal analysis and conclusion.\n"},"changes":[],"summary":"First saved snapshot. No earlier version is available for comparison.","summary_kind":"deterministic","summary_metadata":{}}