Decisions of the Toulouse Administrative Court of Appeal dated May 23, 2024

The Toulouse Administrative Court of Appeal issued several rulings on tax procedure last week and, in particular, held that:

-administration required to initiate the adversarial adjustment procedure to adjust the tax liability of a taxpayer who has expressly stated in their tax return that a portion of their income should be treated as exceptional income under the CIMR:Toulouse Administrative Court of Appeal, May 23, 2024, No. 22TL21167

- The surcharge under Article 1728 of the General Tax Code is calculated based on the tax liability after the CICE credit has been applied:Toulouse Administrative Court of Appeal, May 23, 2024, No. 22TL21736

- Since the income derived from an undeclared activity was not identified during the audit, the irregularities found in the audit have no bearing on the tax assessment proceedings: Administrative Court of Appeal of Toulouse, May 23, 2024, No. 22TL00140