Decisions of the Council of State dated December 21 and 29, 2024

In the last two weeks of December, the Council of State issued several tax-related rulings concerning, in particular:

- the effective date of the option to subject the leasing of undeveloped land and unfurnished premises to VAT: CE, 8th and 3rd Ch., Dec. 21, 2023, No. 474042, Cited in the tables

- The classification of New Caledonian Securities Income Tax (IRVM) under the tax treaty between France and New Caledonia: Council of State, 10th and 9th Chambers, Dec. 29, 2023, No. 462713, Cited in the tables

- Determination of overhead costs allocated to a permanent establishment located in New Caledonia (application of Decision No. 2019-819 QPC): Council of State, 10th and 9th Chambers, Dec. 29, 2023, No. 462718, Cited in the tables

- The classification of rent for the purpose of determining the CVAE tax base: CE, 8th and 3rd Ch., Dec. 21, 2023, No. 469209, Cited in the tables