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 benefit of the tax consolidated group. As a result, the parent company is the only one entitled to ask for the reimbursement of the RTC. This decision has been confirmed by two case law, one released by the French administrative Supreme Court in May 2017, the other released by the Versailles administrative court of appeal in July 2017.

• French administrative Supreme Court, May 10th 2017, N°395447, Société Intelligent Electronic Systems
• Versailles administrative court of appeal, July 27th 2017, N°16VE02595, SAS PROVA