In its landmark caselaw, the French Administrative Supreme Court (Conseil d’Etat) rejects the position of the tax administration and validates the eligibility of ancillary tasks necessary to achieve research works.
Subcontracted expenses eligible to the Research Tax Credit (RTC): ending of more than 5 years of tax insecurity!
French R&D Tax Credit (RTC) eligible development activities can be identified at different architectural levels in a complex system. Performing a complexity and eligibility analysis on the different architectural levels
As a reminder, in France, expenditures related to the conception of new collections by an industrial company in the textile, clothing and leather sector qualify for a research tax credit
New administrative guidelines with respect to staff and subcontracting expenses On December 7th, the French Tax Administration (FTA) released new official guidelines with respect to staff expenses (following a public
Since July 1st 2016, tax reassessments by the French tax authority can be subject to a referral procedure to the national RTC commission in order to ease conciliation between taxpayers
RTC: the project used by a company to support its JEI (Young Innovative Company) application is not necessarily eligible to the RTC
The company needs to be able to justify that it led R&D activities the year with respect to which it claims the RTC. In the same spirit, we commented in
Update of the administrative guidelines on staff expenses: towards a convergence between the tax administration and caselaw?
On July 6th, the Tax Administration released an updated version of the official administrative guidelines (BOFiP) concerning staff expenses eligible to the RTC. In its new guidance, the administration softens
RTC tax audit: the Administration has to give to the taxpayer the name of the expert appointed by the French Ministry of Research
During an expertise, the agents of the French Ministry of Research are to be unbiased and independent, as any administrative authority. If the company under audit thinks that an agent
Audits by the agents of the French Ministry of Research: no compulsory open and oral debate with the taxpayer
Every taxpayer is entitled to have an open and oral debate with the tax administration during a tax audit. As for the Research Tax Credit (RTC), the tax administration can
Temporary additional depreciation mechanism to be extended until April 14th, 2017: opportunities for certain R&D and IT investments
The French parliament is currently reviewing a bill for the “digital Republic” that is in the process of extending the temporary additional depreciation mechanism applicable to certain assets for another