Skip to content
FranceFrançais

Subject and court · Supreme court · France

Tax at the Conseil d'État

In 2025, the Conseil d'État issued 756 decisions on tax (2% more than in 2024), that is 10% of its caseload. 72% of the decisions with a stated outcome are dismissals, against 75% before the administrative courts of appeal. The median time is 8 months, against 20 months before the administrative courts of appeal.

Activity year by year

On tax, the number of decisions of the Conseil d'État went from 999 in 2022 to 756 in 2025, with a minimum of 743 in 2024. From 2023 (987) to 2025 (756), that is a decrease of 23%, against a decrease of 15% before the administrative courts of appeal.

Its share of the caseload of the Conseil d'État went from 12% in 2022 to 10% in 2025.

The dismissal rate is 72% in 2025, against 71% in 2022; the median time is 8 months in 2025 as in 2022.

Conseil d'État: decisions on tax per year2022 : Decisions 999 ; 2023 : Decisions 987 ; 2024 : Decisions 743 ; 2025 : Decisions 75602004006008001.0 kDecisions 2022 : 9992022Decisions 2023 : 9872023Decisions 2024 : 7432024Decisions 2025 : 7562025
Conseil d'État: decisions on tax per year
YearDecisionsChangeShare of caseloadDismissal rateMedian time
2022999–12%71%8 months
2023987−1%13%76%8 months
2024743−25%10%80%8 months
2025756+2%10%72%8 months

Series start in 2022, the first full year in which the decisions of the Conseil d'État were published. Share of caseload: share of the subject among all the decisions of the court, computed from 200 decisions a year. Rate and time not computed below 200 decisions in the year.

See also Conseil d'État: all subjects Tax in France

Back to contents

Time to judgment

In 2025, the median time from filing to judgment is 8 months for cases on tax decided at the Conseil d'État: a quarter are decided in less than 7 months, a quarter wait more than 13 months. This median is the same as in 2024.

The median time of the Conseil d'État (8 months) is shorter than that of the administrative courts of appeal (20 months). All subjects together, the median time of the Conseil d'État is 7 months; on this subject it is 1 month longer.

The median time is calculated on 673 judgments and rulings; 83 other decisions of the year are orders, which count in the volumes but not in the times.

  • A quarter of cases decided inless than 7 monthsfirst quartile
  • Median time8 monthsagainst 20 months before the administrative courts of appeal
  • A quarter of cases wait more than13 monthsthird quartile
  • Decisions counted673out of 756 decisions in 2025
Time from filing to decision, Conseil d'État, 2025< 3 months : 3% ; 3-6 months : 22% ; 6-12 months : 46% ; 1-2 years : 24% ; 2-3 years : 4% ; > 3 years : 1%3%< 3 months22%3-6 months46%6-12 months24%1-2 years4%2-3 years1%> 3 years
Decisions by duration in 2025
DurationConseil d'ÉtatAdministrative courts of appeal
< 3 months3%2%
3-6 months22%1%
6-12 months46%14%
1-2 years24%53%
2-3 years4%26%
> 3 years1%4%

Judgments and rulings only, excluding orders; time counted from the filing of the application to the decision. Not computed below 200 decisions in the year.

See also Conseil d'État: all subjects Tax in France

Back to contents

Outcome of the cases

Among the 751 decisions of 2025 on tax with a stated outcome, 72% are dismissals, 26% annul the contested act or grant the claim, and 1% are withdrawals or “no need to rule” decisions, which end the case without a ruling on the merits. On this subject, before the administrative courts of appeal, these shares are 75%, 17% and 4%. 5 other decisions of the year (interim rulings, outcome not stated or classified apart) are left out of the calculation.

The dismissal rate of the Conseil d'État is 3 points lower than that of the same subject before the administrative courts of appeal. Compared with 2024, the dismissal rate on this subject is down 8 points.

Outcomes on tax in 2025
  • Conseil d'État
  • Administrative courts of appeal
  • Dismissed
  • Annulled or granted
  • No need to rule
  • Withdrawn
  • Referred or transferred
  • Other outcomes
Outcomes on tax in 2025
OutcomeDecisions 2025ShareShare: Administrative courts of appeal
Dismissed53972%75%
Annulled or granted19326%17%
No need to rule71%3%
Withdrawn00%1%
Referred or transferred122%5%

Decisions with a stated and classified outcome, excluding interim decisions (expert report, investigation).

See also Conseil d'État: all subjects Tax in France

Back to contents

Same subject before the courts of appeal

The 9 administrative courts of appeal issued 2,254 decisions on tax in 2025 between them, against 756 for the Conseil d'État.

The share of this subject in the caseload ranges from 4% for the administrative court of appeal of Nantes to 12% for the administrative courts of appeal of Paris and Marseille; it is 10% for the Conseil d'État. Among the 4 courts that issued at least 200 decisions on this subject, the dismissal rate ranges from 68% for the administrative court of appeal of Marseille to 81% for the administrative court of appeal of Versailles. The median time ranges from 18 months for the administrative courts of appeal of Paris and Lyon to 27 months for the administrative court of appeal of Versailles.

Decisions on tax in 2025

Share of caseload: share of the subject among all the decisions of the court. Dismissal rate not computed below 200 decisions on the subject; median time: judgments and rulings only, excluding orders, not computed below 200 judgments.

See also Tax in France Conseil d'État: all subjects

Back to contents

The other subjects of the court

This is the most frequent subject of the Conseil d'État in 2025 (756 decisions), ahead of immigration (479) and civil service (473).

Decisions of the Conseil d'État by subject in 2025
Decisions of the Conseil d'État by subject in 2025
SubjectDecisions 2025Share of caseloadDismissal rateMedian time
Tax75610%72%8 months
Immigration4796%82%6 months
Civil service4736%75%7 months
Planning and building permits4616%82%7 months
Public health3835%68%7 months
Employment law2914%83%7 months
Social welfare2644%72%7 months
Environment and agriculture2623%80%10 months
Local authorities and public property1933%––
Policing1041%––
Driving licences971%––
Public procurement631%––
Housing601%––
Education531%––
Elections401%––
Other subjects3,52647%90%7 months

Subject determined from the legal texts cited in each decision; “other subjects” groups decisions without a characteristic text. Detailed pages exist from 50 decisions on the subject.

See also Conseil d'État: all subjects France

Back to contents

Understanding these figures

What these figures count

Of the 7,505 decisions of the Conseil d'État in 2025, 756 fall under tax (10%), based on the legal texts they cite; 3,526 (47%) fall under no identified subject and appear under “Other subjects”.

Frequently asked questions

How many decisions on tax did the Conseil d'État issue in 2025?

The Conseil d'État issued 756 decisions on tax in 2025 (2% more than in 2024), that is 10% of its 7,505 decisions. Since 2022 the total is 3,485 decisions.

What is the median time to judgment on tax at the Conseil d'État?

In 2025, the median time from filing to decision is 8 months for cases on tax: a quarter are decided in less than 7 months, a quarter wait more than 13 months. On this subject it is 20 months before the administrative courts of appeal.

What share of the decisions on tax at the Conseil d'État are dismissals?

In 2025, 72% of the decisions on tax of the Conseil d'État with a stated outcome were dismissals, against 75% before the administrative courts of appeal. The calculation covers 751 of the 756 decisions of the year.

How many decisions on tax did the administrative courts of appeal issue?

In 2025, the administrative courts of appeal of Paris, Marseille and Lyon issued 609, 347 and 305 respectively. The others issued fewer.