Property taxes and the CFE for business premises: The Constitutional Council paves the way for refunds

administration calculating property taxes and the CFE (business property tax) for commercial premises correctly since at least 2022 (for more details: link to the news article).

To avoid requiringadministration correct this error, lawmakers included a provision in the 2025 budget bill that prevents taxpayers from claiming refunds for amounts they had overpaid.

In today’s decision, the Constitutional Council ruled that this provision limiting taxpayers’ right to file complaints is unconstitutional (Constitutional Council, Nov. 28, 2025, No. 2025-1174 QPC).

Taxpayers who have paid property taxes and the CFE are therefore advised to file claims.

For the year 2024, the claim must be filed by December 31 of this year.

With regard to the CFE for the years 2022 and 2023 and the property tax for the year 2023, a litigation strategy could justify seeking a refund for those years.

Finally, it appears thatadministration the same error when calculating the CFE and property tax for 2025. A claim for a refund could also be filed in this regard.

Since our firm has previously assisted clients with this type of litigation, please feel free to contact us if you would like our assistance.

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.