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
A specific decision, concerning service companies’ Research Tax Credit (RTC), with two levels subcontracting
In the case at hand, pharmaceutical companies (principals) entrusted R&D operations to Hays Pharma (HP), a service company certified by the Ministry of Research. However, the latter did not carry
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 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
2018 RTC Guide: towards more clarifications, in particular regarding the identification of the scope of eligible R&D activities
As a reminder, this guide, which does not have any legal or regulatory value (and is not enforceable against the administration) is intended to help companies in their Research tax
Parliament adopts second amended finance bill for 2017 and finance bill for 2018
On 21 December 2017, the French parliament adopted the second amended finance bill for 2017 and the finance bill for 2018. These finance laws—the first of President Macron—are intended to
Finance bill for 2018 and innovation: what’s up ?
Among the means implemented to support both public and private investment and innovation, the finance bill for 2018 refers to the Big Investment Plan, « Grand Plan d’Investissement » (GPI), representing an
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