(analysis period: March-April 2024)
Industrial plants
TA Clermont-Ferrand, March 8, 2024, no. 2300956 (unfavorable)
To challenge the cost price calculation determined by the French tax authorities, the company argues that the cost prices entered on its "Model U" declarations are consistent with public data on the breakdown of the investment cost of a wind farm. However, by relying on general public studies carried out by the Commission de Régulation de l'Energie and the Syndicat des Energies Renouvelables, the company is unable to identify with any precision the costs that could be dissociated from those falling within the scope of the property tax, and therefore does not usefully challenge the cost price determined by the Administration for the wind farm it operates. The same applies to the reconstitution of the cost price of the wind farm's foundations, based on the volume of the foundations and an average cost per m3 from the experience of the EDF Renewables group.
TA Montpellier, March 18, 2024, no. 2201985 (unfavorable)
Three invoices are at issue in determining whether the equipment is taxable. The invoice dated February 28, 2014 from company B... corresponds to masonry for the construction of a framework, roofing, cladding and isothermal panels for the renovation of the building, falling within the scope of 1° of article 1381 of the CGI. The invoice from company A... corresponding to a door and its electrical equipment, and that from Eurl F... corresponding to the renovation of the lighting wiring, the replacement of lighting fixtures in the cold rooms, the departure and packaging and preparation halls, the rest room, the refectory, electrical security, air conditioning in the refectory and the rest room, relate to equipment that does not appear to be specifically adapted to the applicant company's activities. Consequently, the company does not justify that the equipment in question is not taxable.
TA Versailles, March 21, 2024, no. 2110173 (unfavorable, in this case)
The investigation has shown that the premises in question have the characteristics of a warehouse with a total surface area of 56,728 m², used for the storage, reception, preparation of orders and dispatch of fresh, extra-fresh, seafood, butchery and poultry products, as well as fruit and vegetables. The warehousing area is made up of a number of goods receiving cells, temperature-controlled according to the nature of the goods, and equipped with machines for scanning, customer identification and pallet photo-taking, as well as weight control to validate order preparation. The warehouse is also equipped with refrigeration facilities, a laboratory for automated grading and checking of weight, penetrometer, sugar content and acidity of fruit and vegetables, a waste treatment recovery area, 3,873 pallet spaces for fresh produce, 1,688 pallet spaces for fruit and vegetables, 433 racks with an average height of 7 meters, creating 1,299 storage spaces. In addition, in order to manage the large flows of goods generated by the processing of 130,000 parcels, 80 incoming trucks and 120 outgoing trucks per day on average, staff are permanently using 45 handling and lifting machines to load and unload trucks, store goods in dedicated areas and prepare orders, and are equipped with voice-activated headphones indicating the route to follow to pick up products. Finally, all warehouse activity is based on the use of a centralized warehouse management computer system, which enables all procedures to be processed using voice headsets linked by radio frequency to the central computer in real time, in that the designated staff picks up a code at the indicated location and sends it back to the computer system to obtain the quantity of goods to be picked, enabling, in particular, stocking carts to position themselves at the designated locations to deposit or pick pallets of goods on the different rack levels according to the volume of products stored. Thus, contrary to what the applicant company maintains, the role of the technical installations, handling and lifting equipment used within this establishment is predominant and intended to ensure the storage, preparation and dispatch of orders to the stores. Under these conditions, the tax authorities were right to conclude that the establishment in question was industrial in nature within the meaning of article 1499 of the French General Tax Code.
TA Marseille, March 22, 2024, no. 2200340 (unfavorable)
On July 2, 2012, the applicant company benefited from a partial asset contribution (APA) from SA AF... Subsequent to this APA, on the same day, the Swiss group K..., acquired all the shares in the applicant company. As the APA was carried out between two companies, the applicant company and company A..., both controlled by the same company, SA AF..., the group's parent company, the applicant has no grounds for claiming that the French tax authorities wrongly applied the 11-percent provision to it.th and 12th paragraph of article 1518 B of the CGI. The fact that the two separate and successive transactions were provided for in a single agreement dated May 22, 2012 and carried out on the same day for the same purpose has no bearing on the validity of the taxes at issue, since the ABS predates the sale of the shares. Furthermore, for the application of the 12th paragraph of article 1518 B, control of the transferor company and the transferee company by the same company must be assessed at the time of the transfer of the tangible fixed assets. Consequently, the fact that at 1er The fact that on 1 January 2013 the applicant company and AF... were no longer controlled by the same company has no bearing on the validity of the taxes at issue.
TA Nantes, March 22, 2024, no. 2004114 (favorable)
It follows from the invoice dated January 26, 2009 from SARL P... and the invoice from société J..., which are sufficiently precise, that the corresponding fixed assets relate to maintenance work and must be analyzed as deductible expenses despite their entry in the accounts as fixed assets. As a result, they should be excluded from the basis of assessment for property tax on built-up properties and business property tax.
TA Bordeaux, March 28, 2024, no. 2202681 (favorable)
It is undisputed that the landfill cells in question are not part of the installations mentioned in 1° and 2° of article 1381 of the General Tax Code, insofar as they are not masonry structures and are intended neither to house goods nor to store products, but rather to promote the transformation of the waste buried there by decomposition and methanization. Furthermore, it is clear from the investigation that, for the purposes of its business, the applicant company has built landfill cells on the Lapouyade site. These consist of a one-meter-thick layer of clay, sealed with membranes and fitted with drains to collect leachate and biogas, which is then treated or disposed of. Once filled, these cells are covered with a layer of watertight clay and planted with vegetation. These cells are used to spread and compact final waste. The cells, which are specific facilities required for the industrial process of landfilling waste, are therefore indispensable for the industrial activity of the landfill site, and are required under environmental regulations for the creation of such industrial sites. Consequently, they must be considered as specifically adapted to the activities likely to be carried out in an industrial establishment within the meaning of article 1499 of the CGI. The applicant company is therefore entitled to argue that the cells are exempt from property tax on built-up properties on the basis of 11° of article 1382 of the CGI.
TA Lille, March 28, 2024, no. 2101855 (favorable*)
By an agreement dated November 12, 2004, the company P..., now the applicant company, and the company R... merged, the former having absorbed the latter. Consequently, and without prejudice to the fact that the formalities relating to the land registration of the transfer of the assets resulting from this merger-absorption agreement were not carried out, since this circumstance can only have an impact on the determination of the taxpayer, in accordance with the provisions of articles 1402 and 1403 of the CGI, and not on the tax base, the applicant company is entitled to argue that the rental value of the tangible fixed assets acquired following this merger operation must be determined in accordance with the provisions of article 1518 B of the CGI. Furthermore, it is clear from the investigation that the fixed assets recorded under the headings "Automatic doors", "Conveyor frame", "Supply and installation of two extractors", "Sectional door", "Workshop ventilation", "Factory layout electricity", "Factory electricity", "Welding test ventilation", "Computer room server room air conditioning", "High voltage cabin", "Power supply for lighting and sockets" and "Forced ventilation system" correspond to assets specifically adapted to industrial activities likely to be carried out in an industrial establishment, within the meaning of Article 1499 of the General Tax Code, and which are not among the items mentioned in 1° and 2° of Article 1381 of this Code. The applicant company is therefore entitled to claim that they are exempt from property tax on built-up properties, pursuant to article 1382, 11° of the CGI.
* This favorable ruling was obtained by the G.A.C. Group's partner lawyers and tax team.
TA Pau, April 11, 2024, no. 2101463 (unfavorable, in this case)
The applicant company maintains that the seasonal nature of its business, which implies little use of certain technical equipment, gives the activity a non-industrial character. However, while the majority of the company's storage capacity consists of vertical silos, made up of cells whose loading necessarily involves the use of major handling equipment, and whose operation is subject to strict fire and explosion risk prevention regulations, which make it necessary to ensure, This criterion of frequency of use of the technical means cannot be considered as sufficient in itself to assess whether or not these means are preponderant in the exercise of the applicant company's activity. Moreover, while the loading of these silos is seasonal, since it takes place at harvest time, their unloading takes place frequently and requires material resources which, although less important than during the filling phases, notably involve loading bushels. Under these conditions, the applicant company must be considered to have used, in the course of its business, technical resources that were not only substantial, but also played a predominant role in its operating process. It follows that the tax authorities were justified in considering that this company was carrying on an industrial activity within the meaning and for the application of the provisions of article 1499 of the CGI.
TA Pau, April 15, 2024, no. 2201514 (unfavorable)
In order to contest the surface area used by the Service to calculate the business property tax for the years in dispute, the applicant company maintains that only 57,570 m² of the 137,860 m² of the total surface area of the real estate complex it owns is used for its industrial activity, the remaining surface area not supporting any construction and being essentially used for green spaces. However, the company has only provided an undated aerial photograph, which does not show that the additional 80,290 m² of land that was included in the tax base in dispute was not directly necessary for its business activity. Under these conditions, the applicant company has no grounds for claiming that the Service wrongly included these areas in the surface area used to calculate the rental value on which it was assessed for business property tax.
TA Lille, April 19, 2024, no. 2003037 (unfavorable, in this case)
The applicant company operates as a wholesale distributor of frozen foods, in premises covering an area of 2,600 m². It is clear from the investigation that the company has 554 m² of dock space on these premises, in the so-called "positive cold" zone at 0°C, and a 1,284 m² freezing chamber, in the so-called "negative cold" zone at -20°C, for the needs of its business, The Administration specifies, without being contradicted, that this freezing chamber is controlled from a room housing the computerized, centralized and automated machinery, and that the cost price of the components of these refrigeration systems amounts to 467,592 euros. It is therefore clear that these cold production facilities, which are essential to the applicant's business as a distributor of frozen food products, must be considered as significant technical resources in terms of their market value. Furthermore, in view of the indispensable nature of the cold rooms for the applicant's business and the surface area occupied by these installations, which represent more than half of the total surface area of the premises, they must also be considered as having a preponderant role in the company's business. Under these conditions, the tax authorities were able to qualify the establishment operated by the applicant company as an industrial establishment within the meaning of article 1499 of the CGI, without committing an error of assessment.
Business premises
TA Paris, March 5, 2024, no. 2110735 (unfavorable, in this case)
Since the covered parking lot in question is not, in this case, the hotel's own parking lot reserved for its guests, but a public parking lot with an independent entrance, managed by a third-party company with which hotel guests reserve their parking spaces, the surface area of the parking lot must be considered as being used separately from the rest of the building used for hotel operations, and therefore taxed under the corresponding sub-group III category. The tax authorities were therefore right to tax the surface area of the parking lot under the "covered parking lots" category.
TA Grenoble, March 18, 2024, no. 2106202 (unfavorable, in this case)
The Administration may validly use a term of comparison located in the commune of Villefranche-sur-Saône (Rhône) to value a property located in the commune of Echirolles (Isère) provided that, from an economic point of view, the commune of Villefranche-sur-Saône is sufficiently comparable to the commune of Echirolles in terms of the number of inhabitants, its surface area, and the employment and unemployment rates for the 15 to 64 age group. In view of the similarity between these two municipalities, there is no need to assess the similarity between Villefranche-sur-Saône and Echirolles in terms of the urban areas to which they belong.
TA Clermont-Ferrand, March 22, 2024, no. 2000600 (unfavorable, in this case)
The Lemptegy Volcano Park complex comprises four buildings on a single, enclosed, fenced site: - Building A, which houses an independent restaurant on the first floor, as well as two projection rooms, two exhibition rooms, an infirmary, sanitary facilities, a checkroom and laundry facilities, and offices, archives and a boiler room on the first floor; - building B, which houses an exhibition room, a cinema, a garage and storage space on the first floor, and two bedrooms and a storage space on the first floor; - building C, which houses a "La mine" screening room that has been closed to the public since October 2018; - building D, not open to the public, which houses a garage, a workshop and storage space. It is clear from the investigation that the park's customers pay a single entrance fee paid at the ticket office located at the site entrance, which constitutes the only access, the second being reserved for firefighters according to the plan produced by the applicant company, enabling them to benefit from all the services and activities on offer (exhibition areas devoted to vulcanology, cinema room, "La mine" fun attraction) in the various buildings and in particular to have access to the souvenir store open on the same days and at the same times as the park. As a result, the premises operated by the applicant company on the same fenced-in site form part of the same topographical grouping, with the exception of the restaurant, which is used separately, as the Administration has held. By simply maintaining that the buildings are physically separate, the applicant company has not established, although it is the only one in a position to provide justification on this point, that buildings A, B and D should be considered, in view of their layout, as constituting fractions of property intended for distinct uses within the meaning of the provisions of article 324 A of Appendix III to the CGI and requiring separate valuation.
TA Lille, March 22, 2024, no. 2104307 (unfavorable, in this case)
If, in order to apply the direct assessment valuation method, the applicant company invokes an acquisition price of 2,050,200 francs on February 2, 1999, i.e. 312,550.97 euros, an index 216 on February 2, 1999, and a price of 1,050,200 francs on February 2, 1999, i.e. 312,550.97 euros.th quarter 1969, corresponding to a purchase price of 389,499 francs, or 59,379 euros at January 1.er This value, corrected by a discount for immediate depreciation of 10 % to take account of the constraints imposed on the property in the deed of sale, a discount for obsolescence of 42 % to take account of depreciation of the building at the minimum rate of 2 % over the period February 1999-December 2020, and an adjustment of -10 % due to the nature, size, use and location of the building, resulting in a corrected market value of 22,564 euros (59,379 euros x 0.38), a 1970 cadastral rental value of 1,579 euros (8,464 euros x 7 %), a cadastral rental value (base 1er January 1970) for the years 2018 to 2021 of 5,065 euros, 5,176 euros, 5,238 euros and 6,247 euros respectively, resulting, after taking into account the neutralization coefficients, in a "planchonnement" for the years 2018, 2019, 2020 and 2021 of -74,547 euros, -74,514 euros, -74,885 euros and -73,455 euros respectively, However, in its declaration no. 6660-REV dated February 4, 2022, it mentions improvements carried out since the acquisition of the building, in particular construction work carried out between 2000 and 2007 in the amount of 152,784.33 euros and building additions between 1999 and 2018 in the amount of 518,717 euros. Nothing in the file shows that the difference in rental value after taking these improvements into account would be negative at the end of the planchonnement equal to the updated and revalued 2017 1970 rental value minus the neutralized revised rental value, divided by two. Similarly, there is no evidence in the file to suggest that the revised gross rental value for each of the years concerned, reconsidered by the applicant on the basis of a weighted surface area of 13,863 m² in the "DEP 2" category and 900 m² in the "DEP 3" category, would result in a tax overpayment.
TA Lille, March 22, 2024, no. 2106350 (unfavorable, in this case)
In order to determine the 1970 rental value of the applicant company's commercial premises in the commune of Loison-sous-Lens, the tax authorities, using the comparative method provided for in 2° of article 1498 of the General Tax Code, decided to use standard premises no. 6 in the report on commercial premises in the commune of La Bassée, which has roughly the same number of tax households as Loison-sous-Lens and, in economic terms, a roughly similar population distribution, with trade, transport and miscellaneous services accounting for 70 % for Loison-sous-Lens and 64.7 % for La Bassée. This retail premises, with an actual surface area of 381 m² and a weighted surface area of 210 m², is comparable with the applicant company's premises with a weighted surface area of 160 m². By applying a coefficient of -10 % for the difference in marketing area, the rate of 9.15 euros/m² is reduced to 8.23 euros/m². However, this rate is higher than the 6.25 euros/m² used in the partial admission decision.
TA Montreuil, March 25, 2024, no. 2007853 (unfavorable)
For the valuation of a warehouse/office building straddling the communes of Tremblay and Roissy-en-France, the tax authorities suggest using the following standard premises for comparison purposes: nbones 80 and 84 of the Aulnay-sous-Bois commune minutes. The first is a warehouse building with a weighted surface area of 2,988 m², and a unit rental value set at 15.24 euros/m². The second is an office building, with a weighted surface area of 240 m², and a unit rental value of 25.92 euros/m². In terms of surface area, these properties are comparable to the building at issue and, contrary to what the applicant company maintains, are located in a commune that is in a similar position to Tremblay in terms of economic attractiveness. The fact that the building being appraised has a dual use, as a warehouse and offices, can be taken into account by calculating the unit rate corresponding to the two standard premises taken together, taking into account the surface areas respectively allocated to each use.
TA Clermont-Ferrand, March 28, 2024, no. 2100162 (unfavorable, in this case)
With regard to the unoccupied part of a building, the applicant company mentioned in its declaration no. 6660-REV-K that the company T..., which last occupied the building, carried on a mechanical business described as "ATE" ("Ateliers et autres locaux assimilables"). While the applicant company argues that in reality the activity carried out was industrial, it merely states that, according to Infogreffe, T...'s business was "industrial mechanics" and limits itself to invoking the importance of the technical resources required for this activity, without providing any evidence to support this. Moreover, the photographs alone, which were not time-stamped and did not provide an overall view of the building's interior, were not sufficient to establish that the building's vacancy was accompanied by the disappearance of all industrial technical resources, making the building available for another activity. Consequently, the building could not be appraised under article 1499 of the CGI.
TA Rouen, March 29, 2024, no. 2303115 (unfavorable)
If the applicant company maintains that its building had, even before the completion of the work carried out on it, already lost its status as a superstore on December 1, the company is entitled to claim that the building had already lost its status as a superstore on December 1.er Although the property was acquired on January 1, 2022, the investigation shows that it remained unused for several years prior to its acquisition. Although the company asserts that, as of December 14, 2021, the premises were actually used for the storage of non-hazardous products, and that this activity did not require any specific conversion work, it does not prove this. The mere fact that, as a result of a non-competition clause, the company has prohibited itself from returning the property to commercial use is not sufficient to consider that it had necessarily become a storage facility by the reference date. Thus, the nature of the premises, in commercial use, remained unchanged until completion of the change of use works in June 2022, even though the property was vacant. Contrary to what the applicant company maintains, the fact that there was no tenant and no use of the premises only characterizes the existence of such a vacancy or non-use, and does not presume a change of use on June 1.er January of the tax year.
TA Montpellier, April 2, 2024, no. 2303962 (unfavorable)
While the parties agree that the property in dispute belongs in the "DEP 1" category, corresponding to "open-air storage sites and land for commercial or industrial use", the applicant company persists in considering as its main surface area a 20 m² area corresponding to a room in which all reservations are managed, and the rest of the uncovered caravan storage area in part secondary. However, it is clear from the investigation that, although it was decided to carry out the administrative tasks associated with the company's business in the 20 m² room on the site, this business essentially consists of the physical storage of caravans. Since it is undisputed that this storage takes place on a surface area of 12,204 m², this must, notwithstanding the fact that customers do not have access to it, be qualified as the main part as corresponding to that essential to the exercise of the activity to which the site is totally or mainly assigned. In the circumstances of this case, the remainder of the surface area, including the traffic areas, should be considered as a secondary part. Consequently, in dividing the total surface area into "P1" of 12,204 m² and "P3" of 6,228 m², the French tax authorities did not misapply the provisions of article 1498 of the CGI.
TA Versailles, April 2, 2024, no. 2110312 (unfavorable)
The only remaining contentious issue concerns the classification of a 4,000 m² area as a "P1" zone, corresponding to the main parts essential to the company's business, i.e. areas where materials are processed and handled. The applicant company maintains that only 612 m² or a maximum of 1,000 m² can be classified in this category, corresponding to the surface area of the 512 m² hangar, made up of three mobile elements in poor condition and a fixed part, and an uncovered part of around 100 m² for handling around the crane. However, in support of this allegation, the company has merely produced a bailiff's report dated November 25, 2020, which only quantifies the undisputed surface area of the kitchen garden, and confines itself to noting the presence of a mobile shed in poor condition and rusty, and Algeco-type structures, on the other hand, a certificate of measurement of surface areas by a surveyor dated November 26, 2020, evaluating the surface area of the fixed part of the hangar at 137.5 m² and the other sanitary buildings, changing rooms, offices and storerooms at 264.9 m², i.e. a total of 402.4 m². On the other hand, aerial photographs produced by the tax authorities show that the applicant company carries out processing and material handling operations well beyond the hangar area, and that its activity is not limited solely to the production of piles using the dedicated machine. It follows that the area of land essential to this activity cannot be reduced to 612 m², corresponding to a surface area of only 100 m² beyond the hangar, which is much smaller than the radius of action of the crane used to handle the materials and finished products covered by the hangar, In view of the same photographs, these cover almost the entire surface area of the plot, while the traces of assembly and welding operations are present over an area of at least 3,400 m², which must be added to the hangar area, making a minimum total of 4,000 m² in zone "P1". The French tax authorities were therefore right to assess the surface area essential to the company's business at 4,000 m², and consequently subject it to property tax on built-up properties, in application of article 1381, paragraph 5 of the General Tax Code. Furthermore, in view of the foregoing, the applicant company has no grounds for requesting that this area be reclassified as zone "P3", which corresponds to an uncovered secondary area.
TA Nancy, April 4, 2024, no. 2201335 (unfavorable)
If there is a difference in surface area between the standard premises, with a weighted surface area of 5,182 m², and the building owned by the applicant company, with a weighted surface area of 2,968 m², such a difference does not in itself prevent the standard premises from being validly used as a basis for comparison, but justifies, as the Service considered, an upward adjustment of the rental value. Given the proximity of the premises to be appraised to the RN 59, the Service was also justified in considering that they were in a more favorable situation than the standard premises, which were further away from this thoroughfare. On the other hand, as the applicant points out, the specific features of the term of comparison, unlike the premises in dispute, justified a downward adjustment. However, in view of all these circumstances, it follows from the investigation that the Service has correctly applied the provisions of article 324 AA of Appendix III to the CGI by adjusting the rental value of the standard premises upwards by applying a coefficient of 10 %.
TA Grenoble, April 12, 2024, no. 2106726 (favorable, in this case)
While the tax authorities point out that the towns of Echirolles and Illkirch are not similar in economic terms or population size, they are both located on the outskirts of a major urban area, Grenoble and Strasbourg respectively, and are part of urban areas with similar economic situations. In addition, the population sizes of the two metropolises are similar. Given the nature of the establishments in question (hypermarkets), these factors make the geographical areas in which they are located comparable, even though the two towns concerned are far apart. Furthermore, it is clear from the investigation that the premises type no. 4 listed in the "ME" report for the Illkirch commune, proposed by the applicant company, corresponds to a hypermarket with an actual surface area of 55,880 m² and a weighted surface area of 15,757 m². It is undisputed that this term of comparison also has characteristics similar to those of the establishment to be appraised, in particular its location in a shopping center. As a result, standard premises no. 4 in the "ME" report for the Illkirch municipality constitutes a relevant term of comparison.
TA Versailles, April 26, 2024, no. 2401022 (unfavorable)
To contest the 1.3 location coefficient, the applicant company argues that the location of the plots in question alongside the A6 freeway exposes it particularly to air and noise pollution, as shown by the Airparif map in the file. However, such a circumstance has no bearing on the assessment made by the Commission départementale des valeurs locatives, given that these plots are used for warehousing, storage and parking, and are not intended for residential or customer use, and that their proximity to major roads is an advantage in view of the nature of the activity carried out on these plots. It is also clear from the plans provided that the plots are located close to two stations served by a new tram-train line. In addition, it is clear from the documents in the file that the plots in question are located within an economic activity zone that has benefited from an upgrade of its networks and facilities, likely to offer services to the companies located on the zone. While the company contests the existence of crèches, public canteens and certain public services, it does not contest that the site has been upgraded or that private catering and other business services are available.
Residential premises
TA Marseille, March 22, 2024, no. 2203380 (unfavorable)
To request that the maintenance coefficient used to calculate the rental value of her dwelling be reduced from 1.10 to 0.90, Mrs. B. points out that her house is in a mediocre state, and invokes in this respect the existence of numerous disorders in connection with the work completed on July 31, 2019, in particular problems with waterproofing, the facade and plumbing, recounted by the minutes of the expert meeting before the Marseilles Judicial Court dated July 21, 2021. However, it is not seriously disputed that these problems do not result from the state of maintenance and obsolescence of the property, but from defects linked to the construction of the building during the work carried out up to July 31, 2019. Consequently, the circumstances invoked by the applicant are not such as to challenge the maintenance coefficient of 1.10 adopted by the tax authorities pursuant to article 324 Q of Appendix III to the CGI.
TA Marseille, April 19, 2024, no. 2204536 (unfavorable)
With regard to the combined provisions of articles 324 G, 324 H and 324 O of Appendix III to the CGI, the applicants are challenging the classification in 3th category of their house and swimming pool, which they felt should be classified in lower categories: categories 5 to 7 in terms of the architectural character of the building, and categories 4 or 5 in terms of the quality of the construction, citing the dilapidated appearance of the building and the absence of a crawl space. However, on the one hand, it is clear from the property's valuation sheet that the tax authorities have chosen 4th category and not the 3th category. Furthermore, the photographs in the file show that the exterior walls of the house have not been plastered, so the concrete block exterior is provisional and, even with the alleged absence of a crawl space, does not demonstrate that the category 4 classification would be erroneous.
Article written by:
Clément CARRAY - Local tax expert at G.A.C. Group
As a senior consultant in local taxation, I acquired my technical and specific expertise as soon as I completed my Master II degree. Since 2009, I have been able to handle a wide range of specific situations (more than 100 assignments a year) and develop my experience in line with changes in legislation, regulations and case law. My day-to-day work consists of analyzing my clients' tax bases, making recommendations and suggesting potential optimizations, and assisting them in implementing these actions.
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