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French Court of Appeal Clarifies Loss Carryback May Not be Utilized Following Transformation of Business Activity

|Approved Changes|France
France

The Administrative Court of Appeal of Toulouse issued a decision on 14 November 2024 concerning the ability of a company to carry back losses following a transformation of real business activity. The case involved Immofaq, a French company, that sought to carry back a loss incurred in 2013 against its taxable income in 2012. The tax authority rejected the claim due to a significant change in business activity. Immofaq sold its business in November 2012 and decided to change its name, registe…

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