Registration Document 2013
Consolidated Financial Statements And Notes
Note 39.4. Tax audit at Accor SA
A tax audit is currently in progress at Accor SA. On December 26,
2013, the tax authorities notified the Company of proposed
adjustments to its 2010 accounts. The proposal was timed to
interrupt the statute of limitations that was due to expire for claims
by the tax authorities on December 31, 2013. The tax authorities
have not yet provided any indication of the financial consequences
of the proposed adjustments for the tax group of which Accor
SA is the filing entity, but the total risk including late interest is
estimated at €26 million.
The tax authorities are challenging the independent valuation of
the Accor Services brands that was used by Accor SA to calculate
the taxable capital gain on the brands contributed at the time of
the Group’s demerger in 2010. They have also queried the alleged
waiver by Accor SA of income due by its wholly-owned Brazilian
subsidiary, Hotelaria Accor Brasil S.A., which they say had corporate
income tax and withholding tax implications. This represents a
relatively minor risk.
Accor SA wrote to the tax authorities in February 2014 contesting
the proposed adjustments, but has nevertheless recorded a
contingency provision of €11 million in its 2013 financial statements.
Note 39.5. Other claims and litigation
In the normal course of its business, the Group is exposed to claims,
litigations and proceedings that may be in progress, pending or
threatened. The Company believes that these claims, litigations
and proceedings have not and will not give rise to any material
costs at Group level and have not and will not have a material
adverse effect on the Group’s financial position, business and/or
results of operations.