For those interested in transfer pricing and the tax cap, it is worth noting two rulings by the Administrative Court of Appeal:
A ruling regarding the determination of an interest rate between related companies that exceeds the rate specified in Article 39 1, 3°:Administrative Court of Appeal of Douai, March 6, 2025, No. 23DA01753
Another ruling concerning the deadline for claiming a refund of the tax shield credit. The Nantes Administrative Court of Appeal holds that the repeal of the ISF constitutes an event within the meaning of Article R*196-1(1)(c) of the General Tax Code, which allows for the opening of a new claim period: Nantes Administrative Court of Appeal, March 11, 2025, No. 24NT02322