For the second year consecutively, the Finance Act has reduced the base of eligible expenses for the CIR. Elimination of the doubling of the base for public research as of
Subcontracted expenses eligible to the Research Tax Credit (RTC): ending of more than 5 years of tax insecurity!
In its landmark caselaw, the French Administrative Supreme Court (Conseil d’Etat) rejects the position of the tax administration and validates the eligibility of ancillary tasks necessary to achieve research works.
Research Tax Credit – A disappointing “counter-expertise”
When the tax administration requests a new expertise from the Ministry of Research, nothing prevents that it can be executed by the same experts, even when it is qualified as
Research Tax Credit (RTC) claimed by a certified company: towards a broad appreciation of the amounts to be deducted
The amounts received on behalf of research activities invoiced within a collaborative research program must be deduced from their RTC basis. In the case at hand, the company GENFIT, a
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
Tax incentives for research and innovation in France and worldwide
Issues In a few years, the system of private research funding in France has shifted from a system dominated by subsidies (80% subsidies, 20% taxation in 2000) to a tax
What cost for researchers worldwide?
France leads the way in terms of R&D staff growth – the United Kingdom is working to keep up On September 30th, 2016, the French National Agency for Research and
Entry into force of the national RTC commission
Since July 1st 2016, tax reassessments by the French tax authority can be subject to a referral procedure to the national RTC commission in order to ease conciliation between taxpayers