The French Supreme Administrative Court (Conseil d'Etat) issued a decision on 13 March 2025 dismissing an appeal concerning, among other things, the interaction of the French controlled foreign company (CFC) rules and the provisions of the 1980 income and capital tax treaty with Mauritius. The case involved Rubis Energie, a member of a tax-integrated group headed by Rubis, which was the subject of an accounting audit for the financial years ended in 2012, 2013, and 2014. At the end of the audit, the French tax authority determined that its profit should, for those financial years, be supplemented by income from...