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
Annabelle Caron
With a background in political sciences and finance, Annabelle is specialised in Research Tax Credit in France and abroad, in the GI3 practice in Paris.
+33 1 55 61 41 03Annabelle Caron
Deloitte Société d'Avocats
Research and Development
With a background in political sciences and finance, Annabelle is specialised in Research Tax Credit in France and abroad, in the GI3 practice in Paris.
France
CICo: Publication of administrative doctrine and launch of a public consultation
On Thursday, April 13, the tax administration published in the Official Bulletin of Public Finances (Bofip) the doctrine regarding the CICo scheme, which has been in effect since January 1,
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.
Debate on the orientation of public finances: the RTC in the Economic and Finance Ministry sights
Towards a reduction in the rate applicable to general and administrative expenses? As part of the debate on the orientation of public finances in view of the 2020 Finance law
Ministry of Finance considering introduction of new R&D tax incentive
Content provided by Deloitte Germany Germany’s Ministry of Finance (MOF) is considering issuing a legislative proposal that would provide for the introduction of a new research and development (R&D) tax
R&D operations carried out by a certified subcontractor on its own account may be included in its Research Tax Credit (RTC) basis.
This decision adds to caselaw relating to the calculation of the RTC by principals and their certified subcontractors. The French State Council recently ruled that a service provider certified by
Nature of the work eligible to the Research Tax Credit (RTC) for the principal: eligibility of analytical studies and tests entrusted to a subcontractor called into question even if they were necessary to achieve research work
The National Federation of Seed Multiplier Farmers (FNAMS) subcontracted analytical studies and tests and included the corresponding expenses in its RTC basis. The Court considered that the subcontracted work could
The reimbursement of the RTC has to be requested by the parent company
Within a tax consolidated group, the parent company is the only one entitled to deduce research tax credits received by its subsidiaries on the corporate income tax computed on the
RTC – A first degree case law against the eligibility of retirement benefits
Last June, the Montreuil administrative court decided not to consider retirement benefits as eligible to the research tax credit (RTC) in case of a voluntary leaving of a retiring employee.
The reimbursement of the RTC can be requested by the assignee of the RTC receivable
When the RTC granted to a company exceeds its corporate tax due, the taxpayer has a receivable against the public treasury that cannot be immediately reimbursed, except as permitted by