Decisions of the Council of State dated October 25, 2024

Last Friday, the Council of State issued several decisions:

- With regard to the penalty for willful noncompliance imposed on a legal entity and the principle of individual liability for penalties, the court held that the executive’s knowledge of tax rules and the facts characterizing the executive’s violation of those rules may be taken into account: Council of State, 8th and 3rd Chambers, Oct. 25, 2024, No. 473809, Cited in the tables

- Regarding the classification of extraordinary income under the "blank year" provision during the transition to withholding tax: CE, 8th and 3rd Divisions, Oct. 25, 2024, No. 490089, Cited in the tables

- Regarding the accumulation of social security contributions for pensions in a Franco-Swiss context: CE, 8th and 3rd Divisions, Oct. 25, 2024, No. 473997, Cited in the tables