France Administrative Court of Appeal of Toulouse Clarifies Cost Deductions for Construction of Future Housing

The French Administrative Court of Appeal of Toulouse May 21 issued Decision No. 24TL01798, clarifying cost deductions for the construction of future housing. The taxpayers, a real estate company and its manager-shareholder, applied the progress method and deducted costs that the company paid related to the construction of future housing units. The tax authorities applied the completion method instead and denied the deduction. The manager sought relief from the additional income tax and penalties, which the Administrative Court of Nimes denied. On appeal, the Administrative Court of Appeal of Toulouse found that:1) the manager should have known the rules on ...