Deloitte Société d'Avocats

Precision of the RTC technical documentation

During a tax audit, when a company submits to the Administration several groups of projects divided into several sub-projects, batches and research topics, the Administration is entitled to control the eligibility of research expenses of each division without being limited to a global analysis of the main projects.

In the case at hand, the tasks performed within the sub-projects addressed different objectives, and each project involved spe-cific technological locks that were dealt with separately by the company.