France Administrative Supreme Court Clarifies Payroll Tax Treatment of Corporate Officer Remuneration

The French Administrative Supreme Court May 12 issued Decision No. 502034, clarifying the payroll tax treatment of remuneration paid to corporate officers. The taxpayer, a regional branch of Credit Agricole, challenged additional payroll tax assessments for 2017 and 2018, on remuneration paid to its general managers. The Administrative Court of Montreuil and Administrative Court of Appeal of Paris rejected the taxpayer’s claim. On appeal, the Administrative Supreme Court found that: 1) under the General Tax Code in effect until Aug. 31, 2018, payroll tax applied to all sums that, though not subject to social security contributions, were subject to the ...