Simulation et déductibilité des management fees
Auteur | Mikaël Gossiaux |
Il est frÈquent pour une sociÈtÈ d'avoir recours, dans le cadre de sa gestion, ‡ des sociÈtÈs de management. Ces derniËres ont pour objet social l'assistance, le conseil et la gestion d'entreprise. En contrepartie de cette activitÈ, elles perÁoivent une rÈmunÈration que la sociÈtÈ, profitant des prestations, peut dÈduire en frais professionnels.
L'administration fiscale pose un regard particuliËrement suspicieux sur ce type d'opÈration et tente souvent de contester la dÈductibilitÈ de ces management fees.
Le Tribunal de premiËre instance de Bruxelles a, dans un jugement du 8 octobre 2004, eu ‡ connaÓtre des faits suivants : Une sociÈtÈ de placement et de recrutement de personnel a, dans le cadre d'une convention de prestation de services, confiÈ ‡ une SPRL la mission d'assurer l'organisation, la gestion administrative et l'exploitation de son activitÈ. En raison de ces prestations, la SPRL, alors en perte fiscale, obtient une rÈmunÈration, portÈe en dÈduction par la sociÈtÈ de placement. L'administration fiscale rejette la dÈduction au motif que le contribuable ne rapporte pas la preuve de la rÈalitÈ des prestations convenues. Le Tribunal de premiËre instance de Bruxelles a...
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