France Administrative Court of Appeal Clarifies Application of Monetary Erosion Coefficient to Deferred Capital Gains

May 22, 2026, 5:00 AM UTC

The French Administrative Court of Appeal of Paris May 18 issued Decision No. 24PA02866, clarifying the application of the monetary erosion coefficient to deferred capital gains. The taxpayers, a married couple, sought a reduction in 2015 income tax and exceptional high-income tax contributions, arguing that the coefficient should apply to capital gains. On appeal, the Administrative Court of Appeal of Paris found that: 1) the coefficient applied to the acquisition value of the specified securities, reflected the period between acquisition and realization, and didn’t apply to the deferred capital gains; 2) the application of the coefficient to the acquisition value ...

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