In an important ruling, dated 16 March 2021, the French administrative judge dealt, directly and for the first time, with the situation of a professional footballer, establishing a certain number of criteria to determine the relevant conditions to establish and fix reference pay vis-à-vis other players within the same club. In addition, the judge also provided important clarifications concerning the criteria to be used to determine the “analogous functions” of a player within a professional club.
As a reminder, Article 155 B of the French General Tax Code (CGI) makes the tax exemption of the inpatriation bonus conditional on the fraction of the inpatriate’s remuneration subject to income tax being at least equal to that received for “analogous functions”...
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