France Administrative Court of Appeal Clarifies Input VAT Deductibility, Audit Procedure, Treatment of Fictitious Invoices

The French Administrative Court of Appeal of Paris May 29 issued Decision No. 25PA00482, clarifying input VAT deductibility requirements for subcontractor invoices. The taxpayer, a private security services company, challenged additional corporate income tax, VAT, and business value-added contribution (CVAE) assessments following an audit. On appeal, the Administrative Court of Appeal of Paris upheld the additional assessments and found that: 1) the audit procedure was valid because the relevant period was corrected before substantive audit work began; 2) the taxpayer failed to substantiate its entitlement to a competitiveness and employment tax credit (CICE); 3) VAT deducted in advance on unpaid ...