Decisions of the Council of State dated December 17, 2025
Yesterday, the Conseil d'Etat rulings regarding:
Determining the CVAE tax base in cases of percentage-of-completion accounting (Labor Court, 8th and 3rd Divisions, Dec. 17, 2025, No. 496615, Lebon T.)
the transfer of profits in the case of bonds convertible into shares, the application of the free movement of capital, and the express mention thereof (EC, 8th and 3rd Ch., Dec. 17, 2025, No. 491165, unpublished)
administration authorityadministration is assessed based on the amount of such carryforward deficit prior toadministration adjustmentadministration financial results for the fiscal years (Court of Appeal, 8th Chamber, Dec. 17, 2025, No. 495991, unpublished)
the tax credit, and in particular the evidence required to obtain a refund (Council of State, 3rd Chamber, Dec. 17, 2025, No. 451560, unpublished)
The deductibility of expenses related to a capital gain on real estate (Court of Appeal, 3rd Chamber, Dec. 17, 2025, No. 488091, unpublished)
the adjustment mechanism for rental value (Labor Court, 8th Chamber, Dec. 17, 2025, No. 503898, unpublished)
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