The derogatory regime for determining the C3S base for opaque intermediaries is constitutional. - Lexis Nexis

We are happy to announce the publication of our new article entitled “QPC — The derogatory regime for determining the C3S tax base for opaque intermediaries is constitutional”. Written by Grégoire Person and Thomas Le Boucher, this article analyzes the recent decision of the Constitutional Council of 15 March 2024 (No. 2023-1082 QPC) confirming the constitutionality of this regime.

Posted in Tax Law No. 14, April 4, 2024, Act 135, the article explores the implications of this decision for opaque intermediaries, also called commission agents, who benefit from a specific derogation regime for calculating C3S when working with principals within the EU. It clarifies the conditions of this derogation and its non-applicability to non-EU principals.

For a detailed analysis, consult the online version hither.

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