Decisions of the Court of Cassation and the Council of State dated April 2, 2025

Yesterday, the Court of Cassation and the Conseil d'Etat rulings on tax matters concerning:

- the possibility foradministration the reassessment proposal one of the jointly and severally liable debtors, but the requirement that all other procedural documents be served on all jointly and severally liable debtors. The Court clarifies that all jointly liable debtors, even the one who received the reassessment proposal, may raise this procedural irregularity (Cass. com., Apr. 2, 2025, No. 23-14.865, Published)

- the calculation of the time limit set forth in an order authorizing an inspection and seizure procedure (L.16 B) for carrying out the operations (Commercial Court of Cassation, April 2, 2025, No. 23-15.214, Published)

- a ruling concerning the application of the exemption from corporate income tax (CIT) and the value-added tax on corporate activities (CVAE) for a nonprofit organization that has taken out a group insurance policy for employees in the electricity and gas industries (Court of Appeal, 9th Chamber, April 2, 2025, No. 491589, Unpublished)

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Publication of the tax procedure column in the Tax Law Review

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Case-specific decision by the Council of State regarding the presiding judge