Whenadministration grains of rice to turn a restaurant around

An Asian restaurant was subject to a tax audit, during whichadministration that its accounting records were neither accurate nor conclusive.

She then estimated the restaurant's revenue based on the amount of rice the restaurant had purchased from its suppliers and that would have been used in the nine dishes that generated the most revenue.

administration thereforeadministration 7 grams of dry rice are needed to make a piece of sushi and 46 grams of dry rice for a bowl of rice.

The restaurant attempted to challenge these figures all the way to the Administrative Court of Appeal, submitting, among other things, a bailiff’s report.

The Court notes, however, that the quantities of rice recorded byadministration were determined based on the amounts of cooked rice used and weighed by a company partner while preparing sushi and a side dish of rice, in the presence of the auditor, during the inspection."

The judges also noted that "the calculations used to determine the quantities of dry rice used in the various dishes were performed in the presence of a court officer based on the weight of cooked Japanese rice seasoned with vinegar, whereas, during the inspection by the agency, the cooked rice that was used and weighed had not been seasoned with vinegar."

In short, things are looking grim for the restaurant, as its arguments have been rejected and the ordered restructuring has been upheld.

For those who are interested, the same debates exist regarding a gram of coffee or french fries.

CAA Bordeaux, Oct. 21, 2025, No. 23BX02085

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.