CAA rulings on transfer pricing and the tax cap
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