France Administrative Court of Appeal of Paris Clarifies VAT Deduction, Refund Rules for Mixed-Activity Taxpayers

The French Administrative Court of Appeal of Paris March 20 issued Decision No. 24PA03463, clarifying the VAT deduction and refund rules for mixed-activity taxpayers. The taxpayer, a Cayman Islands company registered for VAT in France, sought a refund of the input VAT on fees for the guaranteed use of two boat parking spaces, arguing that it carried out a taxable activity through subletting and qualified for a full VAT deduction without a partial coefficient. The tax authorities denied the refund. On appeal, the Administrative Court of Appeal of Paris found that: 1) the taxpayer carried out an economic activity subject ...