Abuse of rights by evasion of the law: the Conseil d'Etat clarifies the notion of an exclusively tax-related purpose.
In a study published in Les Nouvelles Fiscales (Lamy Liaisons), our lawyers Alexandre Polak, Thibaut Hubert and Arthur Nadot analyze a Conseil d'Etat ruling of November 29, 2024 (CE, 29 nov. 2024, n°487707 B), which broadens the scope of abuse of tax law by artificial interposition of companies.
This is an opportunity to review the scope of the notion of exclusively fiscal purpose, the boundary between taxation and social security contributions, and the practical implications of the abuse de droit procedure.
An essential insight for all tax law practitioners and executives faced with income reclassifications.
Click here to read an extract from the article.
Read the full article in Les Nouvelles Fiscales, n°1374 - April 15, 2025.
