2014 Registration Document and Annual Financial Report - page 294

Financial Statemements
Parent Company Financial Statements and Notes
5
C. Tax group
The tax group headed by Accor SA comprises the following 65 subsidiaries:
ACCOR Afrique
MARCQ HÔTEL
SNC Management Hôtels
ACCOR Centres de Contacts Clients
Mer et Montagne SNC SODETIS
Chammans Finance
SHNM
Sofitel Luxury Hôtels France
Cie d’Exploitation Hôtelière de Bagnolet NMP France
SOLUXURY HMC SARL
Cie d’Exploitation Hôtelière de Roissy NOVOBIENS
SOPARAC
CieToulon. d’Invest. et de Développement ORPA SCI
SOPARFI
CIWLT Succursale France
Paris Clichy
SOPHIA ANTIPOLIS
DEVIMCO
Paris Porte de St-Cloud
SPARHE
Domaine de Marlioz
P.I.H.
Sté Commerciale des Hôtels Économiques
ECOTEL
PRADOTEL
Sté Comtoise Hôtels Brochets
EHS SNC
PROFID
Sté de Construction des Hôtels Suite
EXHOTEL
SA des Hôtels de Tradition Sté Française de Participations et d’Investissements Européens
FIMAKER
SEORIM
Sté Internationale de Participations
GESTAL
SEPHI
Sté Management Intermarques
HOSPITEL
SH 61 QG
Sté Participations et d’Investissements de Motels
Hôtel de Porticcio
SH Du Montparnasse SNC Sté Participations d’Île-de-France
HOTEXCO
SH de Thalasso Côte Varoise Sté de Participations Financières d’hôtellerie
ibis
budget
SH Forum
SUDAIX sci
ibis Style Hôtels
SH Porte de Sèvres
THALAMER
IBL
SHEMA
Immobilière Perrache SNC
SHORET
La Thermale de France
SIDH
Lionest SCI
SIGEST 1
D. Provision recognized in accordance with
Article 312-1 of standard CRC 99-03
In 2014, Accor applied Recommendation 2005-G issued onOctober 12,
2005 by the French National Accounting Board’s Urgent Issues
Task Force concerning the conditions applicable for recognizing
a provision within a parent company that has set up a tax group.
Under the Group relief agreement between Accor SA and its
subsidiaries, the tax benefits resulting from the utilization by the
tax group of a subsidiary’s tax losses revert to the subsidiary if it
leaves the tax group.
As required by Article 312-1 of CRC standard 99-03, a provision is
recorded for the Company’s liability when it is probable that the
tax benefit will be transferred as a result of a subsidiary leaving
the tax group.
In practice, over the past five years the majority of the companies
that have left the tax group have done so as a result of a liquidation,
merger or disposal not requiring any transfer of tax benefits.There
has only been one case where the sale of a subsidiary to a party
outside the tax group led to the transfer of a tax benefit.
E. Dividend withholding tax
(précompte)
In 2002, Accor launched a legal challenge to its obligation to pay
withholding tax on the redistribution of European-source dividends.
Until 2004, French parent companies that received dividends from
their French subsidiaries were entitled to a 50% tax credit, which
could be set off against the withholding tax payable on redistribution
of the dividends. However, no such tax credit was available for
European-source dividends.
Accor claimed that the absence of a tax credit on European-source
dividends breached European Union rules.
Ruling on a dispute between Accor and the French State, on
December 21, 2006 theVersailles Administrative Court ordered the
State to refund the
précompte
withholding tax paid by Accor in the
period from 1999 to 2001, for a total of €156 million.
The amount of €156 million was refunded to Accor during the first
half of 2007, together with €36.4 million in late payment interest
due by the French State.
Registration Document 2014
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