Decisions of the Council of State dated July 2, 2025

Yesterday, the Conseil d'Etat several rulings on tax matters, including:

- Proof that there was no improper management in the case of a sale at a reduced price, and more specifically in the case of a sale at a price below market value: Council of State, 8th and 3rd Chambers, July 2, 2025, No. 497011, Lebon T.

- Whether the 25% increase in the tax base for deemed distributed income and income under Article 123 bis complies with the ECHR: Council of State, 8th and 3rd Chambers, July 2, 2025, No. 497945, Lebon T.

- the validity of tax bill on or after January 1, 2017, that do not mention or only partially mention the identity of the issuer when the issuer can be unambiguously identified: CE, Opinion, 8th and 3rd Div., July 2, 2025, No. 502065, Lebon

- the non-collection of social security contributions due to the application of the European Regulation on the coordination of social security systems only when the taxpayer can prove that he or she is enrolled in another social security system at the time the income is received: CE, 8th and 3rd Ch., No. 497676, Lebon T.

- A provision for the management of spent nuclear fuel from a nuclear power plant: Court of Appeal, 8th and 3rd Divisions, July 2, 2025, No. 496816, unpublished

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