Credit Agricole to appeal against Emporiki tax decision-paper

PARIS, March 20 Wed Mar 20, 2013 9:26am EDT

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PARIS, March 20 (Reuters) - French bank Credit Agricole plans to contest a decision by French tax authorities to bar a tax deduction it sought on the sale of its Greek Emporiki unit, newspaper Le Monde said on Wednesday.

Credit Agricole's top management is still making a final decision on filing a lawsuit to challenge the decision, which unexpectedly cost the bank 838 million euros ($1.08 billion), pushing fourth-quarter writedowns to 4.53 billion, the newspaper said.

A Credit Agricole spokeswoman declined to comment.

At issue is whether a change in a tax law passed in August could be applied retroactively to a recapitalisation of Emporiki in July. The law change prevented banks from deducting losses like those suffered by Emporiki ahead of its 2.3 billion-euro capital injection by Credit Agricole.

The capital boost was a condition of Credit Agricole's sale of Emporiki to Alpha Bank of Greece, which closed last month.

Credit Agricole's chief executive Jean-Paul Chifflet complained against the move, which the bank was told of just days before its year-end earnings report, even talking to French Prime Minister Jean-Marc Ayrault about it, the paper said. But Ayrault stood by the government's decision, according to Le Monde.

The challenge would begin at an administrative court but could ultimately be referred to France's highest administrative court or its constitutional court because of the retroactiviy issues involved. ($1=0.7760 euros) (Reporting By Christian Plumb; Editing by Greg Mahlich)

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