The activities included in the base of the CIR correspond to the international definition of R&D (research and development) which was established by the Frascati Manual as part of the OECD.

Allowable R&D activities fall into three categories.

Basic Research activities, that contribute to the analysis of properties, structures, physical and natural phenomena, with a view to organize, using explanatory diagrams or interpretative theories, facts emerged from this analysis.

Applied Research activities, which seek to discern the possible applications of the results of basic research or to find new solutions enabling the company to achieve a specific objective chosen in advance. The result of an applied research model consists of a probationary product, process or method.

Experimental development activities - carried out by means of prototypes or a pilot in order to gather all the information to provide the technical decisions, for the production of new materials, devices, products, processes, systems, services, or for their improvement.
Difficulties and uncertainties in science and technology in areas where the state of the art is well established and present  can result in substantial improvements or innovative products, services or processes. The progress, achievements and finally, the originality of the solution in terms of characteristics and technical performance can be indicators of R&D activity.

Only the prototype which aims to experimentally verify research assumptions, resolving doubts and uncertainties in science and technology, without the concern of representing the product in its final commercial form is eligible for the relief.

Eligibility

To be eligible under the CIR, creating or improving a product, procedure, process, program or equipment, must be original or represent a substantial improvement, and not resulting from a mere use of the state of existing technology. The state of existing technology consists of all the knowledge available to the commencement of work and usable by the skilled individual normally responsible for the field in question, without any need to demonstrate an inventive step.

Only activity aimed at resolving scientific and / or technological uncertainties is taken into account. The challenges must be new and not have already led to solutions.

These difficulties, which are not solely an outcome of the investigatory phases, may be linked to the complexity of scientific work to be undertaken, the result of constraints or scientific/ technological uncertainties (as opposed to economic or commercial changes).

Scientific and / or technological uncertainty  exists if a solution can not be found with the state of the art and established bibliography and having used and exploited all available knowledge. The work should result in an appreciable difference compared to the practice prevalent in the field of application and must be based on a technology that differs from a knowhow currently used in the profession by scientists or engineers. The work should not be the design or implementation of solutions. The concept of operations for R & D does not usually include: work to increase productivity, reliability, ergonomics and information technology portability, and the adaptability of software.

Basic and applied research
The relevance of the contribution (product, process or service) or the mere fact that this contribution is new or innovative is not enough to make the operations of creating eligible CIR.
Broadly speaking, provision and monitoring of the product or service with the user are not regarded as R & D activities.
In principle, a project may be eligible in its entirety. In a development cycle alone operations may justify R & D work during the phases of development and implementation may be admitted to the base of CIR.

Activities not constituting R & D operations eligible for CIR
 Activities related to the product or process within functions or engineering studies and whose main objective is to find markets, improve productivity or profitability, establish pre-production plans or perfect regularity of the production process.
 Study of Engineering projects using existing technology to provide information before any implementation.
 Upon completion of the experimental phase, functioning as a normal production system, a prototype or a pilot.
 The prototype design validation, production on a trial basis, aimed at launching and the organization of production and the cost of the series produced on a trial or " Experimental production"
 The developed materials and tools needed for mass production.
 Educational expenses for tailoring products to changing styles or fashion, studies markets, cost studies.
 The work done by a company to adapt its products to standards, unless the work undertaken meet the definitions of operations for R & D;
 Studies to design a device, mechanism, or even a machine, which lead to the development of technical drawings.
 Education activities and vocational training organized by companies.

Allowable Expenditure

Depreciation

Tax deductible depreciation s for:
 buildings engaged in re search operations acquired with effect from 1 January 1991;
 movable items created or acquired in new condition;
 acquired property leasing:
o - Acquired in new condition by the lessor;
o - Affected directly to research (the amount of depreciation is that practiced by the establishment of leasing);
 The company leasing must issue a certificate (to accompany the declaration No. 2069 A) designating the leased asset, its acquisition value and the amount of depreciation charged.
Note: When a facility is used jointly for research and manufacturing, only the portion devoted to R & D must be used for the calculation of depreciation. The company apportions this according to the time of use. This rate is evaluated according to the most relevant cases: use, surface used ...

Staff costs for researchers and technicians engaged in R & D

The expenditure to be considered are wages, benefits in kind, bonuses and social contributions. This excludes taxes based on wages, profit-sharing or participation that have already enjoyed tax benefits.
Researchers and research technicians assigned part-time or during the year in R & D operations are taken into account in proportion to the time actually spent on these operations.

When these expenses relate to individuals holding a doctorate or an equivalent degree, they are taken into account for twice the amount during the first twelve months following their first
recruitment, provided that the employment contract of these people is indefinite and that the number of employees of the company is not lower than the previous year.

Assignment of staff to research

The salaries of researchers and research technicians assigned full-time to R&D activities are fully taken into account for determining the tax credit.
The salaries of researchers and technicians engaged in research or part-time during the year to R&D activities are taken into account in proportion to the time actually spent on these activities. In this regard, companies should be able to establish the actual time spent on R&D activities, any fixed rate  determination being excluded.

Note: It is rare that a researcher or technician can be regarded as engaged in 100% of eligible research tax credit. Indeed, knowledge and / or techniques already acquired are used to carry out this
work.

Definition of research and development personnel

Article 49 f G of Annex III of the General Tax Code defines the concept of Research and Development staff, which includes researchers and research technicians.

The researchers (doctors or engineers)

These are scientists or engineers working on the creation of knowledge products, processes, methods or new systems.
Engineers are treated as employees who, without fulfilling the conditions for graduation, have acquired that qualification within their company.
Employees whose position meets the following criteria a re considered equivalent to engineers:
 Have been promoted within their company, in accordance with collective agreements applicable in the branch concerned;
 Have received written notification of their promotion to the qualification of engineer;
 Therefore, being placed in the classification relating to engineers and managers (irrespective of possession of a degree);
 Be paid on a scale commensurate with their qualifications;
 Must be affiliated to the pension plan and pension fund managers;
 In addition, exercise the functions of engineers engaged in R&D.

Technicians

The research technicians are people who work closely with researchers to provide support to essential research and experimental development .
The tax instruction defines the level of performance that it is reasonable to expect of technicians as follows. They realize including the following:
- Preparation of substances, materials and equipment for conducting experiments;
- Assistance from researchers during the conduct of experiments and experiences in implementation control of researchers;
- Maintenance and monitoring the operation of appliances and equipment needed for research and experimental development.
These scientists or engineering collaborators must therefore have a Scientific and technical qualification recognized in the industry by a technical or higher professional diploma

In order to identify the personnel included in the base of the CIR, the MESR refers to the Classification of Training Standards established by the Ministry of Education which shows that researchers are at level 1 and technicians are at 2 and 3 .

However, the diploma is not the only criterion for admission of personnel in the base of CIR. So, for technicians not possessing the qualifications required, it is for the company to justify any means in its
possession (validation of experience, pay, position in the company, joining a collective agreement,...) that the staff is a qualified research technician.

Excluding support staff

Other categories of staff (secretaries, sales staff ...) or students (who are not company employees) are expressly excluded from the scope of CIR. The same is true of Staff working in a research project, but not possessing the requisite qualification of a researcher or research technician.
The costs for these personnel are supported through the fixed operating costs at 75% of staff.

4.3 Operating expenses

These are fixed and cover, including staff costs (secretaries, ... sales staff), interns, administrative costs, raw materials etc.
These expenses are fixed at:
- 75% of staff costs which relate to researchers and research technicians;
- 200% of staff costs (wages doubled) which relate to holders of a Ph.D. or an equivalent degree,
during the first twelve months after their first recruitment, with the dual condition that the employment contract is indefinite and that the number of employees of the company is not lower than the previous year.

4.4 R & D Operations entrusted to public

These expenses relating to R & D activities entrusted to public research organizations, to universities or technical industrial centers are treated at double the amount provided that there are no links between dependency recipient company CIR and the body, university or technical industry center .

Bonds of dependence are known to exist between two entities when one holds directly or an intermediary majority shareholding of the other or exercising the power of decision, or when they are under the control of a third company (the second and fourth paragraphs of Article 12 of 39 of the General Tax Code).
Note: The work done by public bodies are not always or even all eligible C.I.R The Technology Resource Centers (CRT) are not treated as centers of industrial technology (ITCs)
and must obtain a license issued by the MESR. Their invoices can be used to double the amount in the base of CIR.

4.5 Operations R & D entrusted to private companies or research experts

Businesses can outsource R & D work with a private company, association governed by the law of 1901 or an individual expert, licensed and located in a Member State of the Union or European Economic Area (EU + Norway and Iceland).
The approval is assigned by the MESR and ensures that the company, association or expert applicant has a R & D potential sufficient to be a subcontractor for third parties.

It is the responsibility of the payer to ensure that the subcontractor is authorized the years during which the works are performed and invoiced.

The request for approval shall be deposited at MESR before September 30 in the year sought

Note: Businesses and experts approved by OSEO are not automatically approved under the procedure of CIR.
The approved firms wishing to benefit from the CIR, should not include in their tax credit claim, R & D for which they charge their customers.

R & D entrusted to public research organizations or private, or experts

Scientists are included in the limit of 2 million euros per company per year.
This limit is increased to 10 million euros for expenses relating to operations of R & D bodies entrusted to public or private research or scientific experts, provided that there is no connection and it is at arm’s length as per, the meaning of the second and fourth paragraphs of Article 12 of the Code 39, General taxes, between the company enjoys the CIR and these organizations.
The bills to be considered in a year, are those relating to the years during which these invoices were issued.
It is the payer to verify the eligibility of work done by the contractor prior to include in the cost base.

4.6 Patents and plant variety rights

Under the patent category, fees paid to patent advice invention and agents with the INPI (National Institute of Industrial Protection) to agents responsible for filing patent directly
abroad if the patent is filed in France, translation costs, various taxes collected on behalf of the lNPl for issuing patents and for the benefit of foreign states or international organizations that provide protection for the invention may be taken into account . For certificates of plant variety, the costs incurred for certification are taken into account.
Note: Costs related to the drawings, models and trademarks, and the licensing are excluded

Depreciation of patents or plant variety rights acquired with a view to carry out R & D

These deductible patent allocations or plant variety rights, acquired to be used in new research and not for their industrialization in the state.
The costs of defending patents and plant variety rights The costs must be incurred subsequent to the execution of research operations to be eligible R&D.
A company can not benefit from CIR only for defense spending patents or plant variety rights.
Expenditure incurred in relation to infringement proceedings conducted by enterprises, and
including legal costs, including salaries of court officers (lawyers, legal experts).
Also eligible, staff costs borne by the company under the defense patents.
The expenditure incurred abroad are eligible under the same conditions when they are taken into account in determining the taxable income in France.

4.7 Expenditure Standards

The costs associated with standardization company’s products are used for half of their amount. They include:
•  wages and benefits related to periods during which employees participate in formal
meetings of standardization;
•  other expenses incurred by reason of such transactions; fixed at 30% of these wages;

• expenditure incurred by the head of an individual enterprise, those mentioned in I of Article 151 of CGI (taxpayers exercising their profession in the context of a Society) and corporate officers for their participation in official Standardization meetings, up to a daily amount of 450 euros per day present for meetings.
The expenses of standardization must be directly related to products or processes production under research and development.
Only eligible expenses related to participation in formal Standardization meetings responsible for setting French, European and global standards . (See list of these bodies in Annex II).

4.8 Expenditure on technology watch

Are considered eligible in the base of CIR expenses incurred by the watch company internally when conducting R & D operations within the limit of 60,000 euros per year.
The technology watch is defined as a process of targeted updating of the systematic collection of information on scientific and technical technological and techno -economic relating to products, processes, methods and systems information to deduce development opportunities.
Among other things, the cost of subscriptions to scientific journals, to bases data, participation in scientific conferences or staff costs generated by the participation in these conferences are eligible .
Expenditure on technology watch is eligible only if they are concomitant with the resulting research operations. A company can not benefit from the CIR for only costs of technological watch that it would expose, or the costs of technology watch that are not related to research. The expenditure incurred abroad are eligible under the same conditions when they are taken into account in determining the taxable income in France.

The term fee collection work related to the development of a new range of products, in accordance with the practices of the commercial sector, must be renewed at regular intervals, known in advance. The work must focus on the development of a new range of products (in terms of materials, designs, shapes and colors that you appreciate compared to the preceding series).
Option for IRC for such expenditure is indivisible, meaning the company must gross all expenses taken into account and be entered in the cases relating to the costs of collection. The company must annex to the statement, a summary breakdown by nature and amount of expenses covered.

To qualify for CIR, companies face the textile -clothing - leather and exercise industrial activity.

The expenses are taken into account:
 Depreciation of fixed assets created or acquired in new condition that directly affect the achievement of such transactions;
 wages and benefits associated with designers and technicians style offices responsible for design of new products and engineers and technicians in charge of production realization of prototypes and unsold samples ;
 Other operating costs set at 75% of these salaries and social security payments;
 filing costs designs;
 The costs of defending the designs, within the limits of € 60,000 per year;
 costs subcontracted by the industry-textiles and leather clothing designers and design offices approved by the MESR, after the Enterprise Directorate -General of Ministry of Economy, Finance and Employment;
! The fraction of the tax credit resulting from the inclusion of expenses above is capped for each company to 200,000 euros a period of three consecutive years.

To be approved, designers and style offices can obtain a folder:
- Either on the site of MESR: http://www.recherche.gouv.fr/cid20358/le -credit-d - impot- recherche -
cir.html ;
- Or with the MESR, DGRI - B1, Division "CIR", 1 Rue Descartes 75231 Paris Cedex 05.
Contact: @ Laurent.nouaze property recherche.gouv.fr - tel. 01 -55 - 55 -89 -94 - fax 01 -55 -55 -86 -41
The list of designers and stylists approved can be found on the website MESR.
For the industry, a particular and detailed guide is online at the site of MESR:
http://www.recherche.gouv.fr/cid20358/le -credit-d - impot- recherche -cir.html
Contact: @ Maryline.rosa recherche.gouv.fr - tel. 01 -55 -55 -83 - 10 - fax 01 -55 -55 -86 -41.

4.10 Treatment of grants

Government grants awarded by the European Union, state or local governments because of CIR eligible operations must be deducted from the calculation basis of the tax credit, the collection year and in proportion to the base under the CIR.
Example: A company receives a grant of € 100,000 to cover expenditure on R & D (80% of the grant) and incurs expenditure of market research and research partners (20% of the grant). The company will deduct a total of € 80,000 as the base for the CIR.

5 CONDITIONS FOR THE BENEFIT OF CIR

(Editor's Note: As a result of the 2008 changes to the scheme, the base concept is no longer applicable but is kept for reference)

The CIR is subject to an annual filing. Where, a business that has exited the scheme, wants to return, it must recalculate its credits tax since the last exit, as if the option had been renewed continuously.
Thus, companies that have not renewed their option for the CIR under one or more years and then who wish to benefit from the new scheme, are required to calculate the CIR in the year of deciding
to benefit again, to calculate the tax credit obtained under this year in same conditions as if they had continuously exercised their option for the CIR.
Indeed, the tax credit recorded during the year back in the device must be calculated in conditions of law, ie taking into account the expenses incurred research where appropriate during the previous two years.
Two cases may arise.
1) If the company is out of the last 5 years or less, it must rebuild its base CIR since its last release;
2) If the company is out for over 5 years, it reconstitutes the two years preceding its new entry into
the device.
This follows the filing of the special declaration on the CI R (No. 2069A form, to withdraw from "business taxes" (EIS) or download from the site of MESR: http://www.recherche.gouv.fr/cid20358/le-credit-d-impot-recherche-cir.html
For companies subject to corporation tax, the statement 2069A must be filed with in time as the statement of balance with the SIE. In practice, for companies whose fiscal year coincides with the calendar year, the filing of the declaration must be made no later than April 15.
For companies subject to income tax, they must attach special statement to annual results no later than April 30.
No record is necessary at the time of filing. It is nevertheless essential to maintain all documents used in calculating the tax credit (records and descriptions work, administrative and accounting documents of the amounts claimed for each post) that will be requested in case of audit or request for mobilization with a bank.

Declaration No. 2069 A, on the CIR

A 2069 declaration has 4 sheets to make or use respectively in the statutory deadlines
as follows:
- Schedules 1 and 2 are for the tax service;
- Schedule 3 should be sent to MESR, DGRI - B1, Division "CIR", 1 rue Descartes - 75231 Paris cedex 05;
- Sheet 4 must be retained by the company.
Examples:
The CIR is calculated on a calendar year, regardless of the tax year of the company and the optionmust be exercised at the latest when filing the statement of balance of the first period ended.

Example 1 : A company has a fiscal year beginning 1 January 2007 to 31 December 2007.

The company CIR statement fior 2007 must be in by 15 April 2008.

At the close of its fiscal year, the company will introduce at the same time the CIR statement for the 2007 year.

Example 3: For a company with a higher first year to 12 months, it must file two CIR statements.

ATTRIBUTION 6, REPAYMENT OF MOBILIZATION CIR
Channeling
The CIR will be deducted from income tax or corporate taxes owed by the company under the years during which it increased its research spending. This allocation is done at the time the payment of tax. If the tax credit exceeds the tax or if the company is negative, the remainder is charged against income tax liability of three years and, if necessary, returned to the expiry of this period.
Immediate repayment
a) new (the starting year and four years)
A new company is a company that is not created through a merger, a restructuring, an extension of existing activities or resume such activities and whose capital, fully paid, is held on an ongoing basis at least 50%:
- By individuals, or
- By a company meeting the same conditions whose capital is owned to 50% less by individuals or by venture capital companies, funds common investment risks, regional development companies, Financial innovation, corporations or sole investment risk at provided that there are no relationships between the company concerned and the latter companies or funds. (The arm's length was set at 4.5 above).
b) For start- ups (as long as they meet the conditions)
To be qualified for JEI, you must:

- Be an SME under the EU definition (less than 250 employees, CA <€ 50 million or total assets <43 M €);
- Have less than 8 years;
- Have a really new (within the meaning of Article 44 e of the CGI);
- Have funds held at least 50%, by individuals or by a company
50% owned by individuals or by venture capitalists, the FCPR, CSD, the IFC, the SUIR or foundations or associations of UP, the research institutions and education institutions and their subsidiaries;
- R & D within the meaning of the dR1 should represent 15% of the company.
c) For the SME growth (as long as they meet the conditions)
To qualify as an SME growth, the company must meet the following conditions:
- It is subject to corporation tax;
- It employs fewer than 250 employees. In addition, it has made an annual turnover below 50 million, a total assets exceeding 43 million euros;
- Its capital and voting rights are not owned as to 25% or more by one or several companies not complying with the requirements of paragraph 2 above, or by companies meeting the requirements of paragraph 2, but whose capital or voting rights held to 25% or more by one or several companies;
- To assess compliance with this requirement, the percentage of capital held by venture capital, the FCPR, CSD, and the FCPI SUIR in the enterprise is not taken into account (provided there is no relationship between the company and these companies or funds);
- It employs at least 20 employees and increased staff costs, excluding those leaders, 15% for each of the two previous years.
Note: For the immediate repayment of its dR1 the company is interested contact the service company tax (EIS) which it depends.
Mobilization
The surplus tax credits not yet charged or reimbursed raised a claim against the State. This claim may be assigned as security restoration or the discount from a credit institution.
(BNP Paribas, Societe Generale Oséo or see details in Appendix II). This claim is however not transferable in part against a debt allegedly to the treasury.
The declaration 2574-SD, for the mobilization of CIR, can be downloaded from the site of MESR
15
(http://www.recherche.gouv.fr/cid20358/Ie-credit-d-impot-recherche-cir.html).

8 Securing CIR through advance notice

Under the tacit agreement of the administration established for taxpayers, a provision allows any company that wishes to consult the administration on the eligibility of a R&D prior to the start of work. It is the application procedure or Ruling tax notice .
The response of the administration must be provided within three months, beyond which an agreement is deemed granted and enforceable in subsequent checks.
This provision is however not mandatory to qualify for the CIR.
To benefit from this agreement procedure the company must submit its application accompanied by a File (downloadable from the site of MESR: http://www.recherche.gouv.fr/cid20358/le-credit-d-impotrecherche-cir.html), the Department of Fiscal Services (DFS) on which it depends, then asking the opinion MESR on the scientific and technical aspects of the project.
Note: The possibility of requesting a notice on the eligibility of a project for the benefit of CIR does not require the company receiving the notice to begin its work. The opinion issued by the administration is only for the research project presented and discussed. Thus, each project may need a for notice request independently.

9 CONTROL

The reality of the allocation to R & D expenses taken into account in determining the CIR can be verified by the tax authorities, but also by the MESR. In this regard, the tax instruction 4 A - 1 -00 21
January 2000 (BO IMB No. 27 of 8 February 2000) said that during an investigation of the CIR, "tax administration is seeking the opinion of MESR assessing each time if the scientific work is necessary."
Thus, only MESR agents are empowered and skilled to assess the eligibility of the work reported in the context of CIR.
The right of claw - back is until the end of the third year following the filing of the special declaration for calculating the tax credit.
A company must be able to produce elements of justification:
 Regarding the qualification of personnel (The Heads of projects to be scientists or inventors );
 Relating to the time spent in R & D. These must be determined individual by individual , draft project, year by year (see model below);
 Reporting on the nature of the work done through the following topics.
- Replace the operation in its scientific and economic context;
- Present state of the art existing bibliographic research and technology watch made;
- Identify objectives, performance to be achieved and the constraints;
- Describe the scientific and technical uncertainties , and technological problems to address;
 describe the work:
- Present the developments made, the modeling, the simulations, testing, the  " Research" prototype (as distinct from " concept validation " prototype not eligible), the means and methods used;
- Do the same for operations carried out by research organizations, Technical centers carrying a mission of general interest, companies or experts approved by the MESR;
- Give information and information from this work, especially testing and " Research" prototype;
- - Show how these works are not covered by a common knowledge to the profession.
o Highlight the scientific and technological progress achieved by showing how the work to accomplish this progress leads to a significant difference compared to the knowledge and practice generally prevalent in the area; submit technical and commercial successes that have resulted
o provide indicators of possible evidence of the R & D (research articles, conferences, ... patents);
o Define, for each project, the associated (human figures project costs equipment ...);
To mention any collaboration with laboratories, Technical research centers carrying a mission of general interest or of Manufacturers (licensed or unlicensed under CIR)
! It is important that companies put in place, real -time monitoring of their projects and associated facilities, in order not to be, restrospective evidence for control or to mobilize their CIR.
Note: The fact that a project is funded by OSEO or is the source of deposit patent does not automatically eligible under the CIR.

10 New reforms for R & D in 2008

Terms of calculation

Starting from 2008, the share increased to 40% and the ceiling of the CIR to 16 million euro removed.
The CIR is sitting only on the volume of R & D by enterprises stated:
- 30% of R & D for the first tranche of up to 100 million euros;
- 5% of R & D beyond the threshold of 100 million euros.

For companies seeking to qualify for the first time, the rate of this tranche is 50% of the year of entry into the device and 40% in the second year. These rates apply to a young company that carries out R & D for the first time and the expiration of a period of five consecutive years under which the company did not receive the tax credit and provided that no arm's length within the meaning of 12 of article 39 between that company and another company having benefited from the tax credit during the same period of five years.

Amendments to the inclusion of certain expenses

- Young doctors: When staff costs relate to persons with a PhD or an equivalent degree, they are taken into account for twice the amount during the twenty first four months (instead of the first twelve months) after their first recruitment, provided that the employment contract of these people is indefinite and that the number of employees of the company is not lower than the previous year.
- Operating costs "young doctors": The rate is still 200% of staff (wages doubled) which relate to persons holding a Ph.D. or an equivalent degree during the twenty first four months (instead of the first twelve months).
- Subcontracted Research: The ceiling is raised from 10 to 12 million euros for expenses relating to operations of R & D entrusted to public research organizations or private, or to scientific experts, provided there is no arm's length, the meaning of second and fourth paragraphs of 12 of article 39 of the General Tax Code, between the company CIR receives and these organizations.
- Patent Expenses : From the declaration of 2008, are eligible within € 60,000 per year, bonuses and contributions or share of premiums and contributions relating to contracts assurance of legal protection for the care of expenses, excluding those carrying a possible sentence, in proceedings relating to a patent or a plant breeders' rights which the company holds.

Treatment of repayable advances

As the declaration of 2008, the advances are deducted from the base attitude, as subsidies. However, they are added to the bases of credit the tax year in which they are reimbursed to the agency that has paid.

Repayment of CIR
The immediate refund is extended for young academics (GAME). The game is a company that meets all the conditions of JEI, except those related to the obligation to achieve 15% of R & D over expenses.
The SET is a directed and / or owned at least 10%, alone or jointly by students holders of less than 5 years of a Master's or Ph.D., or persons affected to of education and research.
It's principal activity is the recovery work that these officers / associates have participated at school or in their features.

Application for Securing the CIR:

Under the new Article 13 CA L tax book procedures, companies are able to seek certainty over the CIR, including the period or the current year.
This procedure is intended to help companies to apply the rules.
If the reporting obligation is not yet incurred, the company is invited to take into account the opinion of the authorities when filing his statement.
Where a declaration has been established on the basis of an application or a misinterpretation, the company may rectify the situation as provided in Article L. 62 tax Book procedures.