France Administrative Supreme Court Clarifies Property Tax Liability, Reassessment Limits for Tenant-Made Constructions

The French Administrative Supreme Court April 3 issued Decision No. 502179, clarifying property tax liability and reassessment limits for tenant-made constructions. The taxpayer, a French company, operated an industrial site under a financial lease and sought discharge from the additional property tax on built properties. The taxpayer argued that it wasn’t the owner, that guidance placed liability on the lessor, and that the reassessment was excessive. The tax authorities rejected the claim. On appeal, the Administrative Supreme Court found that: 1) under financial leases with purchase options, tenant-built assets are taxable in the lessee’s name during the lease with regard ...