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