Decisions of the Council of State dated April 5, 2024

Last Friday, the Conseil d'Etat several tax rulings concerning, in particular:

- Evidence of the interest rate between related companies: CE, 8th and 3rd Divisions, April 5, 2024, No. 471139, Cited in the tables

- The regularity of sending a certified copy of an AMR in lieu of the original: CE, 8th and 3rd Divisions, April 5, 2024, No. 474968, Cited in the tables

The Council also ruled that an association whose statutory purpose isto"oppose all forms of fishing, in freshwater and at sea, whether for commercial or recreational purposes" andto"combat all forms of mistreatment of fish (...) including in the context of fishing activities” has no standing to seek the annulment of parliamentary responses stating that the 5.5% VAT rate applies to the sale“of live farmed fish intended to be released into ponds or bodies of water where recreational fishing is practiced.”

In short, the association's appeal fell flat.