France Administrative Court of Appeal of Nantes Clarifies Deductibility of Doubtful Debts from Intra-Group Financing

December 31, 2025, 5:00 AM UTC

The French Administrative Court of Appeal of Nantes Dec. 23 issued Decision No. 25NT00819, clarifying the tax treatment of provisions for doubtful debts from intragroup financing. The taxpayer claimed a deduction for provisions for doubtful debts owed by its parent company, but the tax authority assessed additional corporate income tax and related penalties after a tax audit revealed that the debt claims were not credible. On appeal, the Administrative Court of Appeal of Nantes held that: 1) the 180,000 euro (US$211,914) provision for doubtful debts was unjustified because the taxpayer failed to establish the existence of a genuine receivable or ...

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