The French Administrative Court of Montreuil, in Jurisprudence Letter No. 22 issued on February 3, 2026, has provided crucial clarification regarding property tax relief available to businesses impacted by the coronavirus pandemic. The ruling, detailed in Decision Nos. 2309183, 2309186, 2309189, 2309190, and 2309191, addresses the conditions under which businesses can claim reductions in their 2021 property tax assessments.
The case involved an airport operator that requested a reduction in its 2021 property tax obligations. The airport argued that important declines in air traffic, stemming from pandemic-related terminal and parking area closures, justified a lower assessment. Initially, tax authorities denied the request, asserting that the closures were voluntary decisions made by the airport.
However, the Administrative Court overturned this decision, establishing a key principle for determining eligibility for tax relief. The court found that property tax reductions are contingent upon the non-use of commercial or industrial buildings extending beyond the taxpayer’s control. This means that temporary closures mandated by government regulations or directly resulting from unavoidable pandemic-related circumstances qualify for consideration.
The court’s ruling emphasizes that the burden of proof lies with the taxpayer to demonstrate that the non-use of the property was not a voluntary business decision, but rather a consequence of the pandemic’s impact. Businesses seeking property tax relief must provide evidence linking the closures directly to the pandemic and demonstrating that these closures were unavoidable.
This decision provides valuable guidance for businesses across France that experienced disruptions during the pandemic and are seeking property tax adjustments. It underscores the importance of establishing a clear connection between pandemic-related events and the inability to utilize commercial or industrial properties.