French tax authorities used the wrong comparables to challenge energy multinational Engie’s pricing of LNG transactions for foreign subsidiaries, France’s top administrative court ruled.
The Conseil d’État’s May 7 ruling dismissed a final appeal by the Minister of the Economy, Finance and Industrial, Energy and Digital Sovereignty against a 2024 Paris Administrative Court of Appeal decision.
The top court confirmed the lower court ruling reducing Engie’s tax bases for corporate income tax and business value-added tax, plus related surcharges, by approximately €124.8 million ($147 million) across the 2011-14 financial years.
And it upheld the cancellation of withholding ...