Paris Administrative Court of Appeal Clarifies VAT Penalties

• On 15 July 2026, the Cour administrative d’appel de Paris (2nd Chamber) ruled in case No. 25PA02676 (SAS RBC), addressing VAT reassessments for 2016–2019, deliberate-default penalties, and the reinstatement of carried-forward losses. [juricaf.org], [legifrance.gouv.fr]
• The Court recorded a partial non-lieu after the tax authority granted a supplementary penalty reduction of €1,735 during the appeal, then rejected the remaining claims, confirming the first-instance judgment. [kohenavocats.com]
• It upheld the 40% surcharge for deliberate default and denied deduction of rent paid for an office in the director’s residence, requiring genuine business consideration for such charges to be deductible. [kohenavocats.com]

Article: The taxpayer, holding company SAS RBC, had sought discharge of VAT reassessments and restoration of deficits for 2016–2017. The tribunal had already issued a partial non-lieu; on appeal, the minister granted a further penalty dégrèvement, rendering part of the claims moot. The Court then confirmed strict conditions for charge deductibility (effective consideration) and the proportionality of the 40% penalty for manquement délibéré. Sources: Légifrance official text, Juricaf, Pappers Justice, and a detailed commentary.