Approval

MESRI position – Approval filing deadline - October 2021

The license application calendar is (again) updated.

For a renewal: Companies already approved must request a renewal of their approval between September 1 and November 30 of the last year granted.

The renewal application file is identical to a first application file.

For a first application: In the case of a first application, the file must be sent to the Ministry of Research between December 15 of the previous year and March 15 of the year requested.

Failing this, approval will be granted for the following year.

An example is given on the website of the Ministry of Research: for approval from 2022, the first application file must be sent to the Ministry responsible for research between December 15, 2021 and March 15, 2022.

Source: https://www.enseignementsup-recherche.gouv.fr/fr/procedure-et-calendrier-pour-le-depot-d-un-dossier-de-demande-d-agrement-au-titre-du-cir-46448


European law - Effect of Brexit on the interpretation of BOFIP in terms of authorization - January 2021

Following the signing of the Brexit agreement, the government gives indications on the case of subcontracting to an approved British research organization.

It is then indicated that these expenses will no longer be eligible for the tax credit in favor of research from 2021, the agreement having been signed by the United Kingdom in 2020 to enter the European Economic Area (EEA). not having been renewed.

In fact, only the subcontracting expenses incurred by public or private service providers established in France, in a Member State of the European Union (EU) or of the EEA (Norway and Iceland) can be taken into account in the base of the CIR.


Case law - Conditions for taking into account R&D expenses by a private CIR-approved subcontractor - September 2020

The Council of State canceled the restrictive doctrine of April 4, 2014 on subcontracting.

This had the effect of obliging approved bodies to include in their CIR eligible expenditure incurred on behalf of eligible third parties, before deducting the invoice amount, with the excess impacting internal project expenditure.

An approved subcontractor can therefore now do without re-invoiced projects in order to declare only operations carried out for its own account, thus benefiting on its internal projects from the same advantages in terms of CIR as any declaring company.

Source: CE, 09/092020, n ° 440523 


Evolution - Application deadline - October 2019

The Ministry of Research and Higher Education has brought forward the deadline for submitting requests for renewal of accreditation. Companies now have until November 30 of the last year granted to submit their file.

Regarding the first requests for approval, the filing date has also been brought forward. Companies applying for CIR accreditation for the first time must send their file to the ministry in charge of research between January 1 and March 30 to obtain accreditation from the current year.

Historically positioned on June 30 until 2015 then on May 31, April 30 then today on March 30, the accreditation of a subcontractor from year N requires more and more proactivity in the assembly of the project.

Source: http://www.enseignementsup-recherche.gouv.fr/cid21182/demande-d-agrements-constituer-le-dossier-et-l-envoyer.html



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