Tag: Audit cost

France vs Office Depot, December 2017, CE, Case No. 387975

France vs Office Depot, December 2017, CE, Case No. 387975

Re-invoicing to a Office Depot France, by the controlling US company Office Depot Inc, of a part of the cost of an audit service, as it related to the internal control procedures of the French company. Office Depot France was audited for the period from 28 December 2003 to 31 December 2005, after which the administration notified it of a VAT reminder and a withholding tax on the re-invoicing by the US company Office Depot Inc. of a portion of the cost of an audit service relating to its own internal control procedures. The cost was not necessary for the operation of Office Depot France and thus not deductible. The charge in question corresponded to an indirect transfer of profits abroad. Click here for translation France vs Office Depot_13_12_2017_387975_Inédit_au_recueil_Lebon ... Continue to full case
France vs. Société Office Dépôt France SNC, Jan 12 CAA No

France vs. Société Office Dépôt France SNC, Jan 12 CAA No

In the case of Société Office Dépôt France SNC, a US company recharged a portion of audit costs to the French company. The court found that such costs were incurred in the interest of the US company only, and were accordingly not tax deductible in France. DEPOT FRANCE SNC _15_10_2013_CAA 12VE00798″ target=”_blank” rel=”noopener noreferrer”>Click here for translation DEPOT FRANCE SNC _15_10_2013_CAA 12VE00798 ... Continue to full case