Decisions of the Council of State dated November 12, 2025

Yesterday, the Council of State issued rulings on tax matters concerning:

- The classification of coworking spaces for purposes of the annual tax on office space (Court of Appeal, 8th and 3rd Chambers, Nov. 12, 2025, No. 494253, Lebon T.)

- The treatment of a California LLC as an SAS (Court of Appeal, 8th and 3rd Chambers, Nov. 12, 2025, No. 502894, Lebon T.)

- the failure to apply Article 123 bis to an entity owned by a professional soccer player in which the player’s image rights are recorded as an asset and whose value exceeds 50% of the entity’s other assets (CE, 8th and 3rd Div., Nov. 12, 2025, No. 501567, Lebon T.)

- the household waste tax (CE, 8th and 3rd Ch., Nov. 12, 2025, No. 501632, Lebon T.)

- the conditions for applying the hotel-style accommodation regime, and in particular the repeal of the BOFiP provision stating that "when the stay is less than one week, the condition is met if cleaning is performed at least before the start of the stay" and the provision stating that "when the stay is less than one week, the condition is met when the linens are at least changed at the start of the stay" (CE, 8th and 3rd Ch., Nov. 12, 2025, No. 498267, unpublished)

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