Decisions of the Council of State dated March 13 and 17, 2026

On March 13, the Conseil d'Etat rulings on tax matters concerning:

‍- the deductibility of losses resulting from embezzlement, particularly those committed through the use of violence, threats, or coercion (Court of Appeal, 9th and 10th Chambers, March 13, 2026, No. 499320, Lebon T.)

- the burden of proof in cases involving distributed income from a trust (Court of Appeal, 9th and 10th Chambers, March 13, 2026, No. 500318, Lebon T.)

- The application of the solidarity levy to non-residents' real estate income, regardless of the income tax bracket (Court of Appeal, 9th and 10th Chambers, March 13, 2026, No. 503496, Lebon T.)

On March 17, it also issued judgments in the following cases:

- Supplementary CIMR and the concept of additional workload for a commercial court clerk (CE, 9th Chamber, March 17, 2026, No. 495008, unpublished)

- Proof of knowledge of the tax assessment to trigger the start of the appeal period (Council of State, 9th Chamber, March 17, 2026, No. 504275, unpublished)

- the application of area weighting factors in calculating rental value for nursing homes (Labor Court, 9th Chamber, March 17, 2026, No. 488206, unpublished)

- Determination of the assessment units for a real estate complex for property tax purposes (Court of Appeal, 9th Chamber, March 17, 2026, No. 488231, unpublished)

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