France Administrative Court of Appeal of Paris Clarifies Limits on Deduction of Carried-Forward Tax Losses

The French Administrative Court of Appeal of Paris April 3 issued Decision No. 24PA05142, clarifying the limits on the deduction of carried-forward tax losses. The taxpayer, a former tax-consolidated group’s parent company, sought to offset profits using losses from the former group. Following a document-based review, the tax authorities reduced the carried-forward losses, and the Administrative Court of Montreuil upheld that reduction by rejecting the taxpayer’s claim. The taxpayer argued that it could combine loss-deduction rules to exceed the annual limit and claimed that the authorities didn’t apply procedural safeguards. On appeal, the Administrative Court of Appeal of Paris rejected ...