OrbitaxFrench Supreme Administrative Court Confirms Horizontal Group May Not be Formed by French Companies Held by Swiss Parents
|Approved Changes|France
The French Supreme Administrative Court (Conseil d'Etat) issued a decision on 20 January 2026 upholding a 1 March 2024 decision of the Administrative Court of Appeal of Paris on whether subsidiaries in France of a Swiss parent company may form a horizontal integrated tax group. Under French law, French companies may generally form a horizontal group if at least 95% held by a French parent. Sub…