Conseil d'État decisions of November 29, 2024
The Council of State issued several rulings last Friday concerning, in particular:
- The finding of an abuse of rights regarding the compensation of a group’s executives through a Luxembourg company (Carmignac case): Council of State, 9th and 10th Chambers, Nov. 29, 2024, No. 487707, Cited in the tables
- The inadmissibility of a request to annul an administrative ruling concerning the tax treatment of BSPCE shares held in a PEA: Council of State, 8th and 3rd Chambers, Nov. 29, 2024, No. 497850, Cited in the tables
- The transfer of a company’s registered office abroad and proof of continued business operations in France: CE, 8th and 3rd Chambers, Nov. 29, 2024, No. 473237, Cited in the tables
- the fact that there are no implications for the application of the CIMR to the liberal professions when the taxpayer cannot control their income or when the income received in 2019 is of a different nature: CE, 8th and 3rd Ch., Nov. 29, 2024, No. 476160, Cited in the tables
- The consequences of waiving the benefit of res judicata, with a distinction to be made depending on whether or not the judgment has been enforced: Council of State, 9th and 10th Chambers, Nov. 29, 2024, No. 469935, Cited in the tables