France Administrative Court of Appeal of Paris Clarifies Taxation of Deemed Distributed Income

The French Administrative Court of Appeal of April 30 issued Decision No. 24PA05110, clarifying deemed distributed income. The taxpayer, a partner in a company, sought discharge of additional individual income tax and social security contributions assessed from an audit. The assessment resulted from the tax authorities taxing amounts in the taxpayer’s hands as a distribution from the company. The Administrative Court of Melun dismissed the taxpayer’s claim after partial relief was granted. On appeal, the Administrative Court of Appeal of Paris found that: 1) the taxpayer failed to establish that the company’s profits reconstructed by the tax authorities were allocated ...