Decisions of the Council of State dated December 19, 2024

Yesterday, the Council of State issued several tax rulings concerning, in particular:

- the determination of the capital gain on the sale of equity securities subject to the 12% withholding tax, and in particular the consideration of reversals and additions to provisions for impairment of securities: CE, 8th and 3rd Divisions, Dec. 19, 2024, No. 494714, Cited in the tables

- the determination of deductible reserves and the possibility of invoking an alternative method before a court (in this case, in the context of reinsurance transactions): Council of State, 8th and 3rd Chambers, Dec. 19, 2024, No. 474782, Cited in the tables

- The tax base for payroll taxes, and in particular payments made to employees on sick leave: Labor Court, 8th and 3rd Divisions, Dec. 19, 2024, No. 490767, Cited in the tables

- the conditions for qualifying for tax deferral when capital gains are reinvested in companies (Art. 150-0 D) and the determination of the consequences in the event of non-compliance with the condition: CE, 8th and 3rd paras., Dec. 19, 2024, No. 493353, Cited in the tables