France Administrative Supreme Court Clarifies VAT, Payroll Tax Treatment of Issuer Commissions, Incentive Payments

The French Administrative Supreme Court April 10 issued Decision No. 500369, clarifying the VAT and payroll tax treatment of issuer commissions and incentive payments within a payment card network. The taxpayer, a French card-issuing company, issued payment cards within an international card network and sought discharge from additional VAT and payroll taxes. The tax authorities excluded issuer commissions and incentive payments from the specified VAT deduction and included them in the payroll tax. On appeal, the Administrative Supreme Court found that: 1) issuer commissions were consideration for services provided by the card issuer and must be included in the VAT ...