Orange SA to Appeal Tax Litigation in Relation to Financial Year 2005
Orange SA announced that it is to appeal tax litigation in relation to financial year 2005. In a judgment dated 4 July 2013, the Administrative Court of Montreuil (France) rejected the Group's motion for judicial review, which was submitted in November 2011, in legal proceedings regarding tax issues following a simplification of the Group's corporate structure in 2005. This operation, implementing a decision to simplify the Group's organization, consisted of a merger (transmission universelle du patrimoine) into France Telecom S.A. (now Orange S.A.) of a French holding company that held about 60 subsidiaries and shareholdings. Orange takes note of this decision that effectively prevents a company from deducting provisions from its taxable income and leads to a second imposition on these same provisions once reintegrated into the Company's accounts. Since the appeal process does not have the effect of suspending payments, the amount of EUR1.952 billion will be paid to the tax authorities at the end of July and an amount of EUR190 million in September, the latter corresponding to additional late interest.
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