Am I eligible for a tax credit for opening my restaurant on a beach in Corsica?

One company actually faced the same issue because it had a facility on a beach in Corsica. However, it had to tear down the building and replace it with a temporary structure in order to comply with the law.

She then requested a refund of the tax credit provided for in Article 244 quater E of the General Tax Code relating to investments in Corsica, in connection with the purchase of this demountable structure.

However,administration denied the refund. They determined that these investments did not meet the requirement that they must“relate to the establishment, expansion, diversification, or fundamental restructuring of a business.”

The Administrative Court of Appeals will, however, rule that the purchase of portable restaurant facilities does indeed constitute a change in the restaurant’s fundamental characteristics and that the expense was indeed eligible for the tax credit.

administration will then state that the requirement for the business to be permanently located in Corsica was not met because the company held only a temporary and revocable permit and occupied public property with a temporary structure.

However, once again, the Administrative Court of Appeal ruled that this condition had indeed been met, since the company“has been conducting its business on Calvi Beach for many years, and this investment, made specifically for the premises in question, demonstrated its intention to operate this facility there on a long-term basis.”

administration cite the structure’s removable nature as grounds for denying the tax credit, since that is precisely a requirement for occupying public property.

The tax credit is therefore granted to the company.

CAA Marseille, July 24, 2025, No. 23MA02821

This monitoring service is provided by Mispelon Avocat, a law firm specializing in tax audits and tax litigation. You can stay updated by subscribing to the newsletter via this link.