France Administrative Court of Appeal of Paris Clarifies Deductibility of EU Single Resolution Fund Contributions

The French Administrative Court of Appeal of Paris April 30 issued Decision No. 24PA05016, clarifying the deductibility of EU Single Resolution Fund (SRF) contributions from the contribution on the value added of companies (CVAE). The taxpayer, a credit institution, sought a partial refund of CVAE, arguing that SRF contributions were deductible banking operating expenses. On appeal, the Administrative Court of Appeal of Paris found that: 1) French regulations classify SRF contributions as taxes and similar payments, which excludes them from the General Tax Code’s exhaustive list of CVAE-deductible expenses; 2) the taxpayer failed to demonstrate any legitimate expectation of benefitting ...