Tax Rulings by Supreme Courts (Week of June 29–July 3, 2026)
Last week, the Conseil d'Etat rulings on tax matters concerning:
The characterization of a preferential tax regime and the treatment of the parent-subsidiary regime in this context under Article 123 bis, as well as the classification of the QPFC as taxation (CE, paras. 3 and 8, June 30, 2026, No. 496618, Lebon T.)
The taxation of a lawyer who is a member of an AARPI in the year of his or her withdrawal (CE, 3rd and 8th Chambers, June 30, 2026, No. 475013, Lebon T.)
The requirement of a direct and immediate link between upstream and downstream transactions in order to be entitled to a VAT deduction (Council of State, 3rd and 8th Ch., June 30, 2026, No. 502593, Lebon T.)
It has also issued case-specific rulings regarding:
The Non-Evidentiary Nature of a Company's Accounting Records (Court of Appeal, 3rd Chamber, June 30, 2026, No. 492019, unpublished)
Property that forms part of the basis for assessing property tax (Court of Appeal, 3rd Chamber, June 30, 2026, No. 490443, unpublished)
the development tax (CE, 8th Chamber, June 30, 2026, No. 505131 et seq., unpublished)
Receipt of Debt Collection Documents (Civil Court, 8th Chamber, June 30, 2026, No. 506548, unpublished)
The requirement for a public assessor’s findings in cases involving a judgment on the assessment of real property for property tax purposes using the method set forth in Article 1498 of the General Tax Code (CE, 8th Chamber, June 30, 2026, No. 508801, unpublished)
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