Deloitte Société d'Avocats

Update of the administrative guidelines on staff expenses: towards a convergence between the tax administration and caselaw?

On July 6th, the Tax Administration released an updated version of the official administrative guidelines (BOFiP) concerning staff expenses eligible to the RTC.

In its new guidance, the administration softens its approach on certain aspects by following recent caselaw on the qualification level of researchers and research technicians by putting forward the notion of acquired experience (without being limited to employees graduated only with a research technician diploma). Interns, trainees and international volunteers’ are confirmed that they can qualified as research staff.

As for young doctors, the administration presents modalities of the regime (for example: possibility to suspend the legal regime in case of sickness, motherhood, adoption or work-related injury) and explains how to calculate the variation of the research staff.