By Renaud ROQUEBERT & Cl\u00e9mence BAUCH\u00c9<\/em><\/p>\n In response to the Covid-19 outbreak, several economic, tax and customs announcements have been Having said that, the mere inventory of the proposed measures is not enough, and it deserves a little Broadly speaking, there are two categories of tax measures: those aimed at deferring or waiving taxes, \u2022 Direct tax payment deferral (Corporate income tax balance, payroll tax and local taxes)<\/strong><\/p>\n The deferral of the next payment of all direct taxes due on March 2020 can be requested by all However, the Minister of the Economy and Finance has indicated that VAT and personal income Furthermore, businesses who have opted for the monthly payment of the business property tax (\u00ab\u00a0CFE\u00a0\u00bb) The government’s swiftness of action on these points is most welcomed!<\/p>\n But does this postponement only concern the March deadlines or also the payments due the following In the event that companies have already paid the March deadlines, the Ministry of Finance has But in what form can the request be made (i.e. submission of a specific form) and within what It should be noted in conclusion on this point that these measures consist in deferring the payment of The effect on the company’s cash flow may be beneficial in the short term, however the tax debt will The announcements from the Government, which may vary if the economic situation were to be \u2022 Direct tax rebate<\/strong><\/span><\/p>\n The government has also planned to allow companies to apply for a rebate of certain taxes. The These rebate requests will, however, be examined on an individual basis. Granted in a more restrictive A priori, these \u00ab\u00a0characterized difficulties\u00a0\u00bb would be assessed by taking into account various factors, such In practice, a specific request for deferral or rebate is available to taxpayers on the website imp\u00f4t.gouv. Practically speaking, given the announced individual examination of files, it would appear that the Practically speaking, we therefore recommend that, in order to compensate for any processing delays, As tax agents working with the tax authroties are also affected by the containment measures in place in However, this announcement was made by the Minister through social networks and press articles. Will In very concrete terms, will this mean that the tax audits that are undergoing and which are subject to These questions are critical, and in the absence of a clear position of the authorities, we strongly Additionally, upon the closure of the courts, litigations before the administrative judge and the judicial In conclusion, the Government has responded to some of the difficulties encountered by businesses We must, however, remain cautious with regard to the practical application of certain measures, and Who is concerned and what are the conditions? By Renaud ROQUEBERT & Cl\u00e9mence BAUCH\u00c9 In response to the Covid-19 outbreak, several economic, tax and customs announcements have been made by the French Government since March 3rd, 2020. The purpose of these measures is to provide exceptional and \u00ab\u00a0immediate\u00a0\u00bb support to all companies facing financial difficulties. […]<\/p>\n","protected":false},"author":6,"featured_media":0,"comment_status":"closed","ping_status":"closed","sticky":false,"template":"","format":"standard","meta":{"_seopress_robots_primary_cat":"","_seopress_titles_title":"","_seopress_titles_desc":"","_seopress_robots_index":"","footnotes":""},"categories":[8],"tags":[],"class_list":["post-4244","post","type-post","status-publish","format-standard","hentry","category-coronavirus-en"],"_links":{"self":[{"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/posts\/4244","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/comments?post=4244"}],"version-history":[{"count":0,"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/posts\/4244\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/media?parent=4244"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/categories?post=4244"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.lh-lf.com\/en\/wp-json\/wp\/v2\/tags?post=4244"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}
\nmade by the French Government since March 3rd, 2020. The purpose of these measures is to provide
\nexceptional and \u00ab\u00a0immediate\u00a0\u00bb support to all companies facing financial difficulties. These measures are
\nfor the most part welcome, and aim, generally speaking, to relieve companies of taxes due in March
\n2020, which is an excellent thing!<\/p>\n
\nanalysis, structuring and a few thoughts of opportunity. This is the purpose of this article.<\/p>\n
\nand those aimed at managing tax audit procedures.<\/p>\nI. Direct tax deferral or rebate measures<\/h2>\n
\ncompanies (or their external accountants) \u00ab\u00a0without justification and without penalties\u00a0\u00bb. Practically
\nspeaking, it means that, as soon as a request for deferral is filed, the payment of these taxes is
\nautomatically postponed until the 16 of June 2020 (three-month deadline).<\/p>\n
\nwithholding tax cannot be included in these measures as this \u00ab\u00a0would be too complicated, too
\nburdensome and with risks for the tax security\u00a0\u00bb. Thus, unfortunately, the payment of these taxes is not
\ndeferred.<\/p>\n
\nare allowed to suspend payments and defer them until the balance is paid, directly through their
\n\u00ab\u00a0imp\u00f4ts.gouv\u00a0\u00bb accounts or by contacting the \u00ab\u00a0Centre pr\u00e9l\u00e8vement service\u00a0\u00bb.<\/p>\n
\nmonths? Given the current situation and subject to further measures, it seems likely that this deferral
\nalso concerns the April 2020 deadlines (i.e. in particular for the payroll tax)… but this remains to be
\nconfirmed.<\/p>\n
\nannounced on its website that it is possible to object to the SEPA direct debit (by contacting the
\ncompany’s bank directly) or to request a reimbursement from the relevant Tax Authorities Business Tax
\nService (\u00ab\u00a0Service des imp\u00f4ts des entreprises – SIE\u00a0\u00bb).<\/p>\n
\ntimeframe? In practice, there are existing procedures for requesting a reimbursement; Are they
\napplicable in the current situation? It is quite likely, but we recommend formally confirming this with
\nthe company’s relevant SIE though.<\/p>\n
\nthe taxes in question.<\/p>\n
\nremain, unless the authorities announce otherwise, but no such initiative has been mentioned at this
\nstage.<\/p>\n
\nlastingly affected, must be carefully monitored on a daily basis. We will be vigilant.<\/p>\n
\nmechanism is therefore different from the deferral mechanism, since the rebate removes part or all of
\nthe tax burden permanently.<\/p>\n
\nmanner than deferrals, they will have to be justified and can only be granted in the event of serious
\nfinancial difficulties.<\/p>\n
\nas the compared amount of monthly sales in 2019 and 2020, the nature (other than tax) and amount of
\noutstanding debts, the cash position, etc…<\/p>\n
\nOn 16 March 2020, the Minister of the Economy and Finance also announced that \u00ab\u00a0no deadline has
\nbeen set for requesting this deferral\u00a0\u00bb.<\/p>\n
\n\u2018immediate\u2019 effect of the measure is more relative. Indeed, to date, no specific deadline has been set
\nfor the processing of applications submitted in the context of the difficulties relating to the Coronavirus
\n– Covid 19.<\/p>\n
\na request for deferral should be submitted in parallel with a rebate request.<\/p>\nII. Tax audit measures<\/h2>\n
\nFrance, the Minister of Action and Public Accounts has announced that ongoing tax audits will be
\nsuspended and that no new audits will be initiated. At the same time, arrangements are reportedly
\nbeing considered for the enforced recovery of tax debts.<\/p>\n
\nthis be officially confirmed? There is no assurance at this stage. Very close attention must be paid.<\/p>\n
\nspecific deadlines are also suspended? Will it be possible, for example, not to respond within the time
\nlimits to a reassessment notice sent a few days before the announcements were made?<\/p>\n
\nrecommend acting as if the ongoing procedures were continuing normally.<\/p>\n
\njudge are also suspended.<\/p>\n
\ntoday. The responsiveness of the authorities and the unprecedented scale of the measures announced
\nshould be enthusiastically welcomed.<\/p>\n
\ncarefully monitor the scope of the most \u00ab\u00a0emblematic\u00a0\u00bb measures, such as tax rebates or the suspension
\nof tax audits.<\/p>\nThis publication has been prepared for general guidance on matters of general interest only and does not constitute professional advice. You should not act on the basis of the information contained in this publication without obtaining specific professional advice.<\/u><\/u><\/span><\/i><\/h6>\n
No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication and, to the extent permitted by law, Lighthouse LHLF, its members, employees and agents do not accept or assume any liability, obligation or duty of care for the consequences of your action or that of any other person acting or refraining from acting on the basis of the information contained in this publication or for any decision based thereon.<\/span><\/i><\/h6>","protected":false},"excerpt":{"rendered":"