Methods for Calculating the Asset Ratio for the Purposes of Article 123 bis of the CGI – A Reassessment is Necessary

In this article published in Le Fiscal by Doctrine, Franck Le Mentec analyzes a recent decision by the Paris Administrative Court of Appeal regarding the calculation of the asset ratio under Article 123 bis of the French General Tax Code (CGI). The court ruled that the ratio should be based on the market values of assets rather than their book values, contrary to administrative doctrine. This decision challenges established interpretations and raises questions about the coherence of the current approach. The article examines the legal implications and potential consequences of this ruling, including its impact on tax administration and affected entities.