France Administrative Court of Appeal of Toulouse Clarifies Payroll Tax Base

The French Court of Appeal of Toulouse Sept. 18 issued Decision No. 24TL00420, clarifying the payroll tax base. The taxpayer, a simplified joint-stock company, sought to discharge payroll taxes in arrears. The Administrative Court of Montpellier denied the discharge and the taxpayer appealed, arguing that its general manager’s salary should be omitted from the payroll tax base because they lacked financial sector powers. On appeal, the Court of Appeal of Toulouse held that: 1) it was clear from the investigation that the taxpayer operated in both the financial and commercial sectors; 2) the taxpayer failed to rebut the presumption attached ...