France Administrative Court of Appeal of Paris Clarifies Taxation of Specified Corporate President Remuneration

March 5, 2026, 5:00 AM UTC

The French Administrative Court of Appeal of Paris Feb. 25 issued Decision No. 25PA00901, clarifying the taxation of remuneration paid to a legal person acting as company president. The taxpayer, a company that was sole shareholder of a second company, sought discharge of VAT, corporate income tax, and late filing penalties, arguing that remuneration it received as president of the second company was VAT-exempt, and that it qualified for a French Polynesian flat-rate regime applicable to certain civil companies. The tax authorities denied relief. Upon review, the Administrative Court of Appeal of Paris found that: 1) a legal person acting ...

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