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French Supreme Court Holds Punitive Damages Pronounced by a U.S. Court for Breach of Legal Obligations May Not be Deducted in France

|Approved Changes|France
France

The French Supreme Court (Conseil d'Etat) issued a decision on 8 December 2023 regarding the deductibility of punitive damages pronounced by a U.S. Court for breach of legal obligations In its decision, the Supreme Court struck down an earlier ruling of the Court of Appeals and held that punitive damages pronounced by a U.S. Court for breach of legal obligations may not be deducted for French tax purposes. French law disallows the deduction of any "pecuniary penalties" imposed on the taxpaye…

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