France Constitutional Court Clarifies Constitutionality of Digital Services Tax

The French Constitutional Council Sept. 13 posted Decision No. 2025-1157 QPC, on the constitutionality of the digital services tax (DST). The taxpayer, a digital services company, challenged the constitutionality of specified DST provisions, arguing that they violated the principle of equality and imposed different tax treatments between companies. Upon review, the Council found that: 1) the provisions don’t impose excessive burdens on taxpayers since the tax is based on income received from providing taxable services in France and doesn’t consider other income taxes companies may be subject to; 2) the provisions don’t subject companies to different tax treatment based on ...