The French Administrative Supreme Court gave its decision on 10 July 2007 in the case of Ministry of Finance v. Société Papillon (No 284785). Details of the decision are summarized below.
(a) Background. Arts. 223A to 223Q of the CGI contain a set of rules that allow French companies that are members of a group to file a consolidated tax return (régime d'intégration fiscale). Under this regime, the parent company may compensate the profits and the losses realize…