The French Administrative Supreme Court Sept. 30 issued Decision No. 474848, clarifying corporate income tax liability for income derived from sublicensing rights to reproduce artwork. The taxpayer, a company, challenged its income tax assessment and corresponding penalties, arguing that sublicensing the right to reproduce artwork at a property it owned constituted asset management rather than professional furniture rental activity. On appeal, the Administrative Supreme Court found that: 1) the taxpayer sublicensed the rights at issue without remuneration, and therefore couldn’t be regarded as carrying out a furniture rental activity under the Commercial Code; 2) the tax authorities couldn’t substitute the ...