Decisions of the Council of State dated September 26, 2025

Last Friday, the Conseil d'Etat rulings regarding:

- the absence of an acquisition of an intangible asset by a company that, as part of a reorganization, pays compensation to a group company and expects to improve its profitability by sourcing from suppliers who, until now, had sold products to it only through that compensated company (CE, 8th and 3rd Ch., Sept. 26, 2025, No. 494985, unpublished)

- (i) the absence of any breach of the principle of impartiality where a member of the court’s bench presided over the departmental direct tax commission in connection with a tax reassessment of a company and, as a member of the court, rules on the consequences of that reassessment for the company’s director (ii) the temporal application of the special statute of limitations under Article L.188 C of the LPF (CE, 8th and 3rd Ch., Sept. 26, 2025, No. 492877, Lebon T.)

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