Top French Court Backs Engie in Case on LNG Transfer Pricing

French tax authorities used the wrong comparables to challenge energy multinational Engie’s pricing of LNG transactions for foreign subsidiaries, France’s top administrative court ruled.

The Conseil d’État’s May 7 ruling dismissed a final appeal by the Minister of the Economy, Finance and Industrial, Energy and Digital Sovereignty against a 2024 Paris Administrative Court of Appeal decision.

The top court confirmed the lower court ruling reducing Engie’s tax bases for corporate income tax and business value-added tax, plus related surcharges, by approximately €124.8 million ($147 million) across the 2011-14 financial years.

And it upheld the cancellation of withholding ...