Without structurally reforming the Research Tax Credit (CIR), the State is refocusing its tax base and revising certain calculation parameters. In March 2024, the General Inspectorate of Finance identified ways
Jean-Charles Reny
Jean-Charles is part of the Research & Development service line (GI3).
After having assisted large international groups regarding various tax issues (M&A, Supply Chain, or operational tax), he has been developing expertise in the field of innovation tax credit.
He manages tax issues related to the research tax credit system for large companies or SMEs in various sectors (health, new technologies, IT, etc.), closely with engineers and scientists, part of Deloitte Société d’Avocats law firm. He supports companies regarding recurring missions (determination and security of the research tax credit, documentation) or on more specific missions of review or assistance in case of tax control.
Jean-Charles also has strong expertise in setting up and managing the favorable tax regime applicable to patents and software (“IP Box”).
01 55 61 62 37Jean-Charles Reny
Deloitte Société d'Avocats
Jean-Charles is part of the Research & Development service line (GI3).
After having assisted large international groups regarding various tax issues (M&A, Supply Chain, or operational tax), he has been developing expertise in the field of innovation tax credit.
He manages tax issues related to the research tax credit system for large companies or SMEs in various sectors (health, new technologies, IT, etc.), closely with engineers and scientists, part of Deloitte Société d’Avocats law firm. He supports companies regarding recurring missions (determination and security of the research tax credit, documentation) or on more specific missions of review or assistance in case of tax control.
Jean-Charles also has strong expertise in setting up and managing the favorable tax regime applicable to patents and software (“IP Box”).
France
CIR – Details on the young PhD regime
The Council of State judges that staff already hired on a permanent contract (CDI), then holding a doctorate, benefit from the young PhD regime, during the first 24 months from
With the publication of the long-awaited implementing decree, the Collaborative Research Tax Credit (CICo) becomes operational
The Finance Act for 2022 introduced a new tax incentive to promote innovation: the Collaborative Research Tax credit (CICo), codified in the article 244 quarter B bis of the CGI.
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 !
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
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.
IRC – The notion of “entrusted” work eligible to the RTC is broader than subcontracting alone.
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
Association Races de France decisions: projects eligibility, subcontracting and technological watch
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