As a reminder, the amounts received by private accredited research organizations as a result of the transactions eligible for the RTC are deducted from the basis of their tax credit
The decision of the Council of State on the Research Tax Credit (RTC) of accredited companies : the deduction of the sums received cannot generate a negative RTC !
RTC : can the French tax authorities disregard a scheme with two levels of subcontracting to challenge the RTC ? the Conseil d’Etat takes position.
The Conseil d’Etat (the French highest administrative jurisdiction), in a decision of 9 June 2020 (no. 427441), judges the case of cascading subcontracts in the frame of the French RTC.
Read more about this: Research Tax Credit (RTC) claimed by a certified company: towards a broad appreciation of the amounts to be deducted The Administrative Court of Appeal of Versailles,
Taxation of proceeds from the assignment or grant of patents: what’s in the new administrative comments ?
As a reminder, the 2019 Finance Act has deeply changed the tax regime applicable to income derived from Patents (Article 238 of the French General Tax Code). In July 2019,
The French-style IP box: reform of the tax regime on the proceeds from the sale or licensing of patents (Art. 14 of the FLP – new Article 238 of the CGI)
The reform of the French regime, which has become inevitable, will be implemented as part of the 2019 Finance Act. It will ensure that French tax rules are in line
This decision released by Paris administrative court of appeal tackles a few topics within the framework of the RTC, among which we can find: The subcontracting expenses in the context