Whenadministration documents marked "not to be shown to the inspector"

A real estate investment company owned a castle that it was offering for rent.

It was subject to a tax audit, a judicial search, and a tax inspection. Following the latter,administration it was engaged in furnished rentals and was therefore subject to corporate income tax and VAT. The SCI’s partner was also assessed for deemed distributed income.

The tax assessments were challenged all the way up to the Administrative Court of Appeals.

The court will find that evidence of the furnished nature of the rentals is evident, in particular,from"business email correspondence and excerpts from the standard lease agreement for the château, marked 'not to be shown to the inspector'."

The Court also notes that the SCI owned"a property complex comprising fourteen suites, luxuriously furnished, which it typically rents out either for group events, such as weddings, or for film shoots."

The Court will therefore uphold the assessed adjustments, except for those relating to the shareholder, for which the reassessment proposal sufficiently substantiated.

CAA Marseille, Nov. 20, 2025, No. 24MA00605

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