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 its approach on certain aspects by following recent caselaw on the qualification level of researchers and research technicians by putting forward the notion of acquired experience (without being limited to employees graduated only with a research technician diploma). Interns, trainees and international volunteers’ are confirmed that they can qualified as research staff.

As for young doctors, the administration presents modalities of the regime (for example: possibility to suspend the legal regime in case of sickness, motherhood, adoption or work-related injury) and explains how to calculate the variation of the research staff.

Thomas Perrin

Thomas Perrin, Partner, specializes in international tax. He has been involved in many transactions for international French and foreign groups. In 2004, he created the R&D department as well as […]

Lucille Chabanel

Lucille has more than 14 years’ experience in tax law. She is a member of the corporate tax department since 2002 and joined the R&D group in 2004. She has […]

Lionel Draghi

Lionel Draghi, Partner and Engineer, is a member of R&D department. Lionel has more than 15 years’ experience as Software Developer and Product Architect in the Industry sector. He has […]

Laurent Gouzènes

With more than 30 years’ professional experience in innovation and research, Laurent was technical and scientific director of several companies, including 18 years as Plan and Study Programs director within […]

Rémi Barnéoud

Rémi has over 20 years of experience in development, project management and strategic advice in the areas of software, electronics, mechanics, and control and monitoring systems. Remi has developed an […]