Decisions of the Council of State dated July 25, 2025

Last Friday, the Conseil d'Etat rulings on tax matters concerning:

- The deductibility of foreign exchange losses and the taxation of foreign exchange gains on dividends received in foreign currency that qualify for the parent company regime: Court of Appeal, 9th and 10th Chambers, July 25, 2025, No. 487722, Lebon T.

- The treatment, in this case, of a British private limited company by shares as a limited liability company (SARL) and the implications for the application of withholding taxes: Court of Appeal, 9th and 10th Chambers, July 25, 2025, No. 489925, Lebon T.

- Deductions applicable under the tax on television service publishers and distributors: CE, 9th and 10th Ch., July 25, 2025, No. 492773, Lebon T. , and No. 492885, unpublished

This monitoring service is provided by Mispelon Avocat, a law firm specializing in tax audits and tax litigation. You can stay updated by subscribing to the newsletter via this link.