Case law on the deduction of a public subsidy in the calculation of the CIR

The judges of the Administrative Court of Lyon (CAA Lyon, September 21, 2023, Groupe Mentor) have ruled, with regard to the CIR deduction of a subsidy, that the company that received the subsidy should have deducted it in full, over and above the eligible expenses incurred on the subsidized project.

The key point to note from this case law is that, according to the judges, non-eligible and non-valued expenses should have been deducted from the company's CIR base.