Tag: Payment on behalf of parent

France vs Yazaki Systems Technologies France, October 2022, CAA de Versailles, Case No. 20VE02286

France vs Yazaki Systems Technologies France, October 2022, CAA de Versailles, Case No. 20VE02286

Yazaki Systems Technologies France (SY France) is wholly owned by the German company SY Systems Technologie Europe GmbH, which became Yazaki Systems Technologie Europe GmbH (SY Europe) in 2013 following the acquisition of 100% of its shares by the Japanese parent company that created the group, Yazaki Corporation Japan. The group develops and distributes wiring harnesses for the automotive industry. SY France was subject to an audit for the years 2012, 2013 and 2014 where the tax authorities denied the deductibility of a compensation of EUR 7,000,000 paid to Renault, which was intended to compensate the latter for the damage suffered as a result of an anti-competitive agreement involving several automotive suppliers, including the Yazaki group. According to the tax authorities SY France’s payment to Renault was made on behalf of the Japanese parent which had negotiated the cartel/anti-competitive agreement. Yazaki France filed an appeal with the Administrative Court which in judgment No. 1802237 of July 7, 2020, rejected its ... Read more