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Jehovahs Witnesses And The Taxation Of Gifts Books In France

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While the associations were hitherto exempt from gift tax on donations they receive textbooks, the tax authorities in France decided in 1998 to tax a nonprofit association of Jehovah's Witnesses. Jehovah's Witnesses have complained of a tax measure they deem discriminatory and were challenged in the courts. Despite criticism in the press against the legal interpretation of the law followed by the tax authorities, that decision was upheld by the national authorities. Ultimately, the matter was brought before the European Court of Human Rights, for "undermining the freedom of religion" and "discriminatory treatment".

Summary

/ / Legal background

Associations and gifts

A gift guide is literally a donation "from hand to hand", which involves the counting of the donor (giver) and enrichment of the donee (the recipient). It is characterized by a donative intent, that is to say, a desire to divest himself without consideration for the other. Also stands there modest donations, which are the cause or counting or enrichment. They also differentiate donations notarized and bequests , since by definition there is no act authenticating transmission.

While the administration has long tolerated this form of financing for associations simply declared that lacked the capacity to receive donations, the law of 23 July 1987 . The declaration must be made on Form No. 2735 issued by the administration.

Section 757 of the General Tax Code, introduced by the Finance Act for 1992 , provides that:

"The proceedings contain the declaration by either the donee or his representatives, judicial recognition of a gift manual are subject to gift tax. The same rule applies when the recipient shows a manual gift tax administration. "

If we examine the preparatory work of the finance law for 1992, it was clear in the minds of the legislature that the provision concerned individuals, especially the taxpayers who are subject to tax on income, and not corporations, such as nonprofit organizations.

Following the new administration made in the fight against sects and the concern expressed by the associations, Article 2 of the Act of 1 August 2003 concerning patronage, associations and foundations was added to Article 757 of the Tax Code the following sentence:

"These provisions do not apply to donations made to textbooks interest bodies mentioned in Article 200. "

Since then, non-profit associations (Act of July 1, 1901) that meet certain criteria of interest, those that qualify for tax relief for their donors, no longer at risk of being taxed on gifts textbooks they receive for registration fees, particularly for audit of accounts.

Legal structure of Jehovah's Witnesses

The cult of Jehovah's Witnesses is organized in France by two types of associations, according to their purpose:

  • Of religious associations within the law of 9 December 1905, which provide national, regional and local practice of worship of Jehovah's Witnesses. One thousand communities of Jehovah's Witnesses, like their national representation , are entitled to receive donations and bequests and to issue tax receipts, which are entitled to a tax cut for donors (sections 200 and 238 bis General Tax Code). As associations of worship, so they are exempt from transfer taxes for free, under Article 795 of the Tax Code, and are therefore not affected by this tax manual gifts.
  • Of non-profit associations declared only by law from 1 July 1901. The Association of Jehovah's Witnesses "(declared on 1 September 1947) belongs to this category of associations that are not considered strictly cultic meaning of the Act of December 9, 1905, as it operated at the national level the printing of books published by Jehovah's Witnesses in France. Before the Act of 1 August 2003 concerning patronage, associations and foundations , these associations do not benefit from any legislation guaranteeing their rights to exemption from such donation. Since this legislative change, the associations show a general interest are excluded from this tax manual gifts.

Thus, of all the associations connected with the cult of Jehovah's Witnesses, only two associations, the Association of Jehovah's Witnesses "(ATJ) and the Christian Community Bthlites have been such a tax adjustment of donated books that are made, always in proceedings before the European Court of Human Rights.

Taxation of the Association of Jehovah's Witnesses "

Tax audit

The Association of Jehovah's Witnesses "has undergone a tax audit conducted by tax authorities, which began Nov. 28, 1995 and ranged up to 18 January 1999. It covered the period from 1 January 1992 to August 31, 1996 . This comprehensive review has confirmed the non-profit activities of the association .

During this fiscal control, the administration noted that the Association of Jehovah's Witnesses "was collected between 1 January 1993 and August 31, 1996 sums of money she has recorded in its accounts under the name of "offerings" .

Notification of tax adjustment

The administration took the view that it was "manual gifts" and that the presentation of accounting documents to the tax officer constituted a "revelation" within the meaning of section 757 of the Tax Code, it has notice to the association to declare the donations within a month. The declaration of donations is not compulsory textbooks , the association has refused to pass such a declaration, which must be made through Form No. 2735 issued by the Administration, which would automatically render taxable gifts.

Accordingly, the Revenue Department of the Hauts-de-Seine south has used the procedure of taxation of office and notified in May 1998 the Jehovah's Witnesses a recovery of 45 million euros, corresponding to half of the rights donation rate of 60% (which applies to donations between non-relatives, in accordance with Article 777 of the Tax Code), plus penalties (80% of the amount claimed) and late interest.

Reactions and controversies

Jehovah's Witnesses make the case public

Monday, June 29, 1998, you could look in the evening daily Le Monde that the Consistory of Jehovah's Witnesses National de France took the initiative to make public dispute between the two years since the Jehovah's Witnesses to the tax , relayed information on the following days in the French press. Indeed, the tax administration has decided to tax manual gifts received by one of its national associations. In a press release the same day, the Christian Federation of Jehovah's Witnesses in France denounced the "exorbitant tax" which is "required on the denier of the cult of Jehovah's Witnesses." She says "this decision is based on a misinterpretation of the law and could affect donations to all religions and all the associations of France."

Later in the week, a press conference chaired by Willy Fautr, president of League of Human Rights Without Frontiers in Brussels, was held July 2, 1998 to denounce a "precedent" dangerous for associations to condemn the unfairness of this "tax dragonnade" . Alain Garay, counsel for the Association of Jehovah's Witnesses and tax lawyer, pointed in particular on this occasion that only 5% of the 800 000 registered clubs in France benefited from tax exemption if they meet the criteria of usefulness public or charitable assistance.

An open letter from the Central College of Jehovah's Witnesses in Brooklyn ( New York ) was sent to the President of the Republic, Jacques Chirac, asking him to "withdraw its support for the tax unfair and discriminatory and thus avoid a dangerous threat against religious freedom and human rights in France. " A full page advertisement was published July 5 in the American newspaper The New York Times and also on July 8 in the U.S. daily published in Paris International Herald Tribune by reproducing the letter under the title: "France moves to tax religion. " Followed by the comment: "The French tax administration has jeopardized the fundamental human rights by imposing a punitive tax of 60% on the 3rd Christian religion in France".

Reactions

Faced with this threat on the main source of funding for associations, associations French expressed deep concern. Religious associations, which do not necessarily cultic recognition, more specifically reacted, as soon as this matter was brought to the attention of the public. Thus the magazine Friends of monasteries she said that "unrecognized communities receiving direct donations textbooks can not issue any tax receipt. Worse, a threat does exist tax against them." And add in a note that "if the association was to be taxed there would be a space of legal discussion to defend against the administration."

More generally, it is simply declared all associations (Law 1901) is concerned. This was confirmed by the Juris Associations in his analysis of Judgement of the Tribunal de Grande Instance de Nanterre (July 4, 2000):

"If it were to be confirmed for any association whatsoever, such a decision would obviously dramatic considering the amount of taxation. "

Bulletin of the Associations and Foundations (published by Editions Francis Lefebvre) also denounced the risks of such a charge:

"This decision constitutes a threat to all associations that are funded in whole or in part by donations from their faithful followers or supporters. In case of tax audit, they will be subject to adjustments (at the rate of 60%) of donated books that their accounts "reveal." If they refuse to comply with the set of notice deposit the printed 2735 declaration of gifts received, a penalty of 80% will be added to the tax, bringing the total recovery to an amount higher than that of donations ... "

One senator asked the government on this new administration, which raises some concerns:

"In various countries, the denier of worship and offerings sent corresponding to various churches and religious associations are considered to be for the recipient, income exempt from taxation. Franois Trucy reminds the minister of economy, finance and industry that allowed religious groups to ensure their activities in their areas. He was surprised that in France the tax office in the Hauts-de-Seine south come to impose a tax on gifts made to Jehovah's Witnesses. To his knowledge, no similar tax was imposed on other churches and religious associations. He questioned the decision was in conformity with the declaration of the European Court of Human Rights. He also fears that this decision sets a precedent that could affect other religious associations. He wondered if the decision corresponds to a circular from the Directorate General of Tax Services or a local initiative. He therefore asked how the tax policies in the field of money worship. "

The newspaper Les Echos has even published the views of counsel under the title "Freedom of association threatened by Bercy"

"In other words, this practice confiscatory death threat all registered associations, large and small, established in France, most of which do not work every day thanks to the generosity of their members or their sympathizers, such as associations of Parents or neighborhood associations, or associations of transmission of a humanistic and spiritual reflection. This extremely violent attack against the world of associations is even more serious because it is based on a legal analysis totally devoid of legal basis. "

Only the intervention of the legislature in August 2003 with the law on patronage, associations and foundations , finally reassure the non-profit associations, stating explicitly that the provisions of Article 757 of the General Code taxes do not apply to charitable bodies.

Reviews of the legal interpretation adopted by the tax

Some legal experts have expressed astonishment at this new practice of charging administrative manuals donations collected by nonprofit associations.

This new interpretation of Article 757 of the Tax Code has been somewhat criticized by all the lawyers for various reasons . The main arguments against the taxation of the association in-depth articles and case notes:

  1. The application to legal persons such as associations, section 757 of the Tax Code would be contrary to the will of the legislature, according to parliamentary proceedings that preceded its enactment. This amendment to the legislation by the finance law for 1992 was to address some tax evasion to tax on income. Indeed, when a tax officer discovered during a tax audit income concealed, the taxpayer relied on donations of textbooks generally avoid tax. This ability to tax ex manual gifts and "revealed" by the taxpayer now allowed to pressure to induce him to present the true nature of such unreported income. This tax provision was essentially an individual, which are taxable income. The fact that the gift tax form manual (form No. 2735) is addressed to individuals and apparently it does not envisage an association may be donee (especially when asked to indicate the degree of relatedness between the donor and the donee) is also used as an example to confirm the traditional practice of government, which exempted the hitherto non-profit organizations of gift tax on donations for their funding.
  2. The presentation of the accounts did not constitute a disclosure within the meaning of section 757 of the Tax Code. According to the Bulletin of the Associations and Foundations , "Since corporations have no tax liability to declare the donations they receive textbooks, the revelation of these gifts can only be optional and left to their discretion. The presentation of the accounts during the tax audit can not be such a revelation. "Journal of Tax Law defends the same view: "The keeping of proper accounts of obols offerings and can not lead a revelation to the Authority in the event of a tax audit. This analysis can be reinforced by two sets of factors: firstly, the common meaning of the concept of revelation, on the other hand, the ratio legis who presided over the adoption of the second paragraph of Article 757 of CGI. "revelation manual gifts could therefore arise as a spontaneous and voluntary taxpayer and not simply a response to a request a tax officer.
  3. The modest grants could also justify the exemption from inheritance tax. This is the point of view that supports Nathalie Peterka, who dedicated a thesis to manual gifts in the directory Defrnois : "It has been argued, on the provisions scarce, they are not donations to because the element of extra-causal liberality lacking. While donations textbooks deplete the donor and enrich the donee, the modest gifts, such as gifts or donations of uses of fruits and revenues, enriches not impoverish either party. It follows that, assuming all donations enrichment and a consequential loss, small donations are not donations Petition of Jehovah's Witnesses

    Following the confirmation to the Supreme Court of taxation and the filing of an appeal before the European Court of Human Rights , Jehovah's Witnesses were launched in March 2005 a campaign of awareness to the pointing of faithful who have made non-anonymous donation (by check or by bank transfer, for example), the taxation of donations to religion and discrimination against Jehovah's Witnesses believe they are victims in this case. A national petition has collected 874,130 signatures on this occasion .

    Parliamentary activity related to the recovery of the debt

    The Court of Cassation upheld the tax relief on donations received manuals by the Association of Jehovah's Witnesses in October 2004 and appealed to the European Court of Human Rights has no suspensive multiply several parliamentary interventions towards the government's incentive to quickly claim a full refund of the tax debt.

    Ministers Nicolas Sarkozy (Interior) and Thierry Breton (Finance) did not answer this time for parliamentary questions about the progress of the recovery of this debt, the member Jean-Pierre Brard filed Oct. 18 2005 an amendment to the draft 2006 budget law to ensure full recovery of this sum to be effective in 2006. The amendment was approved the next day by the Finance Committee (which belongs to Jean-Pierre Brard), although the general rapporteur of the Budget Gilles Carrez (UMP) has reported that this amendment could not receive "any legal effectiveness", since State may be compelled to collect a debt. Jehovah's Witnesses immediately be denied preferential treatment from the taxman. During the parliamentary debates in the National Assembly Jean-Francois Cope (Minister Delegate for the Budget and State Reform) replied:

    "This record is subject to normal processing for the recovery of amounts due. All steps were made. The real estate collateral, consisting of mortgages taken on buildings belonging to the association have been taken by the accountant on time. Installments are already occurred. The recovery of debt continues in order to satisfy the best interests of the Treasury. "

    Put on 24 October 2005, the amendment was not adopted.

    Despite this explanation of the Minister, a dozen parliamentary questions have been raised in questions to the government for clarification on the amount of payments already made under the cover of the 45 million that the Jehovah's Witnesses sentenced to pay the state . Indeed, these deputies and senators were surprised that a regional association of worship of Jehovah's Witnesses have been able to acquire land for the construction of a place of worship Deyvillers ( Vosges ), while they believe the tax debt a national association is not yet settled. To these various questions, the Minister of Economy, Finance and Industry has renewed its response :

    "The legal rules enacted tax secrecy required for taxpayers in the administration. They do not provide all the particulars required when the answer will be published in the Official Journal. "

    At a hearing of Jean-Francois Cope by the Finance Committee in January 2006 Jean-Pierre Brard took the opportunity to ask:

    "What is, finally, the recovery of tax debt of Jehovah's Witnesses? The state could he pledge real property to the sect, as the land it bought Deyvillers, in the Vosges? "

    In response, the Minister said:

    "The issue of tax liability of Jehovah's Witnesses is the subject of greater attention from the Government"

    Legal procedure

    Tribunal de Grande Instance de Nanterre, July 4, 2000

    On November 23, 1999, the Association of Jehovah's Witnesses sued the director of tax services in the Hauts-de-Seine to the southern High Court of Nanterre for the cancellation of the notification and recovery notice was assessed. The nonprofit organization has defended the following main points:

    • Article 757-2 of the Tax Code applies to individuals and not corporations;
    • "revelation" must result from a spontaneous process;
    • lack of "revelation", the association was not obliged to declare gifts received textbooks;
    • the association must qualify for the exemption only for religious associations under section 795-10 of the General Tax Code;
    • by conducting the survey of donor disbursements by computer, the administration has violated Article 31 of the Act of 6 January 1978 relating to data, files and freedoms.

    On July 4, 2000, the Tribunal de Grande Instance of Nanterre confirmed the tax relief and dismissed the arguments presented by the complainant. To this end, the court gave the following reasons including:

    • the law makes no distinction, the gift tax is applicable regardless of the quality of the donee;
    • accordance with the definition of "reveal", which does not distinguish whether the action is spontaneous or coerced, the presentation of its accounts is "revelation" manual gifts that the association has received;
    • the association can not qualify for the exemption provided by section 795-10 of the General Tax Code, since it does not have an official authorization to receive donations and bequests exempt from transfer taxes for free or recognition as a religious congregation;
    • the administration has not broken the law of 6 January 1978 relating to data, files and freedoms, the data obtained by computer means do not identify the donors.

    Jehovah's Witnesses have lodged an appeal before the Court of Appeal of Versailles.

    Court of Appeal of Versailles, 28 February 2002

    The Versailles Court of Appeal upheld the trial decision in its ruling of 28 February 2002 . The main points of his argument to be addressed are:

    • Article 757 of the Tax Code applies to all persons, whether physical or legal, the legislature had set no limits;
    • the amounts credited to accounts classified as "offerings" are many gifts; willingness to contribute to the exercise of religion does not clear donative intent; the modest donation does not preclude the classification of liberality ;
    • presentation of accounting is "revelation" within the meaning of Article 757 paragraph 2 of the Tax Code;
    • statements being printed the transcript of paper documents and computers being used solely for the purpose of shaping the information gathered and editing the document, there is no automated processing referred to in Article 5 the Act of 6 January 1978 relating to data, files and freedoms.

    The judge expressed the occasion are powerless against a law unfavorable to the world of associations: "Considering that, without denying the consequences of the reform introduced by the legislature for the voluntary sector, which derives most of its resources on the generosity of its Sustaining members or sympathizers, it is however not correct or judge to reform the law, if it is inadequate. "

    The association filed an appeal in cassation.

    Supreme Court, October 5, 2004

    In its ruling Oct. 5, 2004 , the Court of Cassation rejected the appeal of Jehovah's Witnesses in all his ways, thus confirming the reasoning of the Court of Appeal of Versailles. The association was ordered to pay costs.

    European Court of Human Rights

    Jehovah's Witnesses filed February 25, 2005 an application with the European Court of Human Rights. The applicant association considers that the taxation on the offerings of worship violates his right to protest and to exercise his religion. She says the importance of the amount due, which exceeds the value of its property, its activities and its existence would be threatened. This case was issued in terms of Article 9 (freedom of religion) of the European Convention on Human Rights , taken alone and in combination with Article 14 (discrimination).

    A similar case has already been brought before the European authorities, but has been discussed by the European Commission and not by the European Court. The Union of Atheists complained of not being allowed to receive a legacy, not being regarded as a religious association under the 1905 law, while two other associations related to it were granted such a authorization. The commission concluded that 22 votes against 4 in violation of Article 14 in conjunction with Article 11 of the Convention:

    part le risque de captation d'hritage, le Gouvernement n'a pas fourni de justification la diffrence de traitement opre par la lgislation franaise en matire de libralits entre les associations cultuelles d'une part et les autres associations d'autre part. La Commission n'aperoit, quant elle, aucune justification objective et raisonnable de maintenir un systme qui dfavorise un tel degr les associations non cultuelles. "

    Il semble finalement que l'tat franais prvoie de trouver une solution amiable dans cette affaire qui l'oppose aux Tmoins de Jhovah . a rvl dans son dition du 1 er novembre 2006 que la MIVILUDES (Mission de vigilance et de lutte contre les drives sectaires) a runi le 20 octobre 2006 les reprsentant de diffrents cabinets ministriels, qui ont propos un possible " amnagement " de la dette fiscale. Ils suggraient notamment de rduire les pnalits de retard. Le 23 octobre, le ministre des Affaires trangres a rpondu la Cour europenne, qui lui a demand de transmettre ses observations : " Le gouvernement franais al'honneur de vous informer qu'il supports the principle of settlement of this matter, and any offer of mediation by the Court (...) to promote the search for agreement between the parties. "According to the newspaper La Croix . The applicant's complaint based on Article 9 of the Convention for the infringement of freedom of religion, became relevant enough to demand a consideration of the merits of the case .

    Taxation of the Christian Community Bthlites

    Community Christian Bthlites furniture has received a contribution of 137 204.12 by private deed dated November 12, 2002. Registered Nov. 28, 2002, this operation has been taxed by the taxing authority in respect of the rights of inheritance tax at 60%, according to sections 750 and 757 ter of the General Tax Code. The association challenged the reassessment notice, saying it is not a gift because she said its onerous nature related to moral and religious counterparts incurred in transferring. Finally, the Court of Cassation rejected the complainant's arguments, concluding that "the burdens imposed on the association by the contribution agreement were more general, no specific and concrete obligation was prescribed, as well transmitted was not assigned to use predefined .

    References

    1. Article 16 of Law No. 87-571 of 23 July 1987 on the development of sponsorship amending Article 6 of the Act of 1 July 1901 relating to the contract of association.
    2. "Donations textbooks," Louis Martin, La Semaine Juridique Edition notarial, 7-14 November 1997, p. 1373.
    3. Article 15 of Law No. 91-1322 of 30 December 1991 introducing Article 757 of the CGI.
    4. Bill relating to patronage, associations and foundations, Report No. 278 (2002-2003) Mr. Yann Gaillard, on behalf of the Finance Committee, filed May 7, 2003, FIRST ARTICLE A (new) :
      "The National Assembly asked that appears explicitly in the law, the exemption of transfer duty of charitable bodies in giving books. In fact, it's back to some interpretations contrary to the traditional exemption that had been made by the tax when it was to fight against sects. "
    5. Law No. 2003-709 of 1 August 2003 concerning the patronage, associations and foundations
    6. "France has 200,000 Jehovah's Witnesses," In France today, Monday, February 4, 2008, p. 17.
    7. Law No. 2003-709 of 1 August 2003 concerning the patronage, associations and foundations
    8. Court of Cassation, Commercial Chamber, 5 October 2004, No. 03-15709, Association of Jehovah's Witnesses.
    9. Jacques Guyard and Jean-Pierre Brard , Report No. 1687 , Committee of Inquiry on the financial, estate and tax sects, and their economic activities and their relationships with business and finance, June 10, 1999, p. 169.
    10. Court of Cassation, Commercial Chamber, 5 October 2004, No. 03-15709, Association of Jehovah's Witnesses.
    11. "Donations textbooks," Louis Martin, La Semaine Juridique Edition notarial, 7-14 November 1997, p. 1373. Information Report No. 1802 (Finance Committee of the National Assembly, September 8, 1999) by Jean-Pierre Brard on "the fight against fraud and tax evasion" (Chap. IV, II. C. 1. b), p. 323.
    12. Jacques Guyard and Jean-Pierre Brard , Report No. 1687 , Committee of Inquiry on the financial, estate and tax sects, and their economic activities and their relationships with business and finance, June 10, 1999, p. 222.
    13. The World, Tuesday, June 30, 1998.
    14. Le Figaro, Friday, July 3, 1998. The Cross, Friday, July 3, 1998.
    15. The New York Times, Sunday, July 5, 1998.
    16. International Herald Tribune, Wednesday, July 8, 1998.)
    17. Friends of the monasteries, No. 117, January 1999.
    18. Juris Associations, No. 225, October 1, 2000, p. 17.
    19. Bulletin of Associations and Foundations, No. 31, September 2000, 254.
    20. Official Journal, Senate, Questions, June 10, 1999, No. 13512, p. 1947.
    21. "The freedom of association threatened by Bercy," Bruno Belouis, Les Echos, Monday, March 5, 2001, p. 69.
    22. Law No. 2003-709 of 1 August 2003 concerning the patronage, associations and foundations
    23. See the list of articles published in the legal press in the bibliography.
    24. Bulletin of Associations and Foundations', No. 31, September 2000, 254.
    25. Tax Law Review, No. 25, 2001 936.
    26. Directory Defrnois, No. 01/02, pp. 10, 12, 13.
    27. Letters of the Christian Federation of Jehovah's Witnesses in France published in Le Monde dated Friday, October 28, 2005 and The Cross of Monday, November 7, 2005.
    28. Finance Act 2006 (No. 2540), Article 51, Amendment No. I - 244
    29. National Assembly, Verbatim Report of the 2nd official meeting of Monday, October 24, 2005
    30. Official Journal, National Assembly Matters, October 19, 2004, No. 48742, p. 8043; Official Journal, National Assembly Matters, January 4, 2005, No. 54842, p. 21, Official Journal, National Assembly Matters, November 8, 2005, No. 77636, p. 10270; Official Journal, National Assembly Matters, January 31, 2006, No. 84578, p. 825; Official Journal, Senate, Questions, February 9, 2006, No. 21611, p. 337; Official Journal, National Assembly Matters, February 14, 2006, No. 85500, p. 1432; Official Journal, National Assembly Matters, February 14, 2006, No. 85691, p. 1436; Official Journal, National Assembly Matters, February 21, 2006, No. 86390, p. 1735 Official Journal, National Assembly Matters, February 21, 2006, No. 86407, p. 1735 Official Journal, National Assembly Matters, February 21, 2006, No. 86607, p. 1739.
    31. Official Journal, National Assembly Matters, May 9, 2006, No. 77636, p. 4945; Official Journal, National Assembly Matters, May 23, 2006, No. 85691, p. 5429; Official Journal, National Assembly Matters, May 23, 2006, No. 86407, p. 5429; Official Journal, Senate, Questions, May 25, 2006, No. 21611, p. 1453, Official Journal, National Assembly Matters, June 13, 2006, No. 84578, p. 6180; Official Journal, National Assembly Matters, August 1, 2006, No. 85500, p. 8089.
    32. Proceedings of the Finance Committee, the general economy and the plan Tuesday, January 24, 2006, meeting of 10 h 45.
    33. TGI Nanterre, July 4, 2000, No. 99/14939, 1st Civil Chamber, Association of Jehovah's Witnesses, published and commented on the RJF in December 2000, No. 1526, see also Michel de Guillenchmidt , "The revelation of donations manual or the Apocalypse tax ", RJF December 2000, p. 905.
    34. CA Versailles, 1st Chamber, February 28, 2002, No. 00-5693, Association of Jehovah's Witnesses.
    35. Court of Cassation, Commercial Chamber, 5 October 2004, No. 03-15709, Association of Jehovah's Witnesses.
    36. Association of Jehovah's Witnesses v. France, No. 8916/05 ( Information Note No. 86, May 2006 ).
    37. v. Union of Atheists France, European Commission of Human Rights, July 6, 1994, No. 14635/89.
    38. Release, Wednesday, December 20, 2006, p. 15.
    39. Cross, Thursday, December 21, 2006, p. 10
    40. Association of Jehovah's Witnesses v. France, No. 8916/05, September 21, 2010.
    41. Reuters, September 29, 2010. Le Monde, 2 October 2010.
    42. Court of Cassation, Commercial Chamber, 7 July 2009, No. 07-21957, Christian Community Bthlites.

    Bibliography

    Legal Sources

    General studies of donated books

    • Daniel Faucher, "Taxation manual gifts: Virtual limitations?" Law & Heritage, No. 82, May 2000, p. 35-37.

    Articles dealing with donations to associations manuals

    • Xavier Delsol, "Gifts textbooks", in Xavier Delsol, Alain Garay, Emmanuel Tawil, Right Worship - People, activities, goods and structures, associations Juris Publishing, Lyon, 2005, pp. 466-487.
    • Alain Garay, Daniel Guizard, The Gifts textbooks associations - legal and tax regimes, Juris Publishing Service, Lyon, 2002.
    • Philippe Goni, "The regime manual gifts" in the Jehovah's Witnesses: Practice and cultic law of 9 December 1905, Editions L'Harmattan, Paris 2004, pp. 93-99.

    Feature articles on the legal textbook donations to associations

    • Bruno Belouis, "Freedom of association threatened by Bercy", Les Echos, March 5, 2001, p. 69.
    • Maurice Christian Shepherd, "What weapon against tax sects?", Journal of Tax Law, No. 25, 2001, pp. 934-939.
    • Xavier Delsol, "Towards a tax on donations to associations manuals?" Juris Associations, No. 225, October 1, 2000, pp. 17, 38-44.
    • Alain Garay, "cultural discrimination", The Posters Parisian, 26, 27, 28 September 1998, p. 14.
    • Michel Guillenchmidt "The revelation of donations tax manual or the Apocalypse," Journal of Tax Cases, December 2000, pp. 905-908.
    • Louis Martin, "The religious associations and article 757 of the new tax code," Legal Week Notaries and Real Estate, No. 15, April 9, 2004, pp. 652, 653.
    • Natalie Peterka, "The taxation of gifts textbooks associations declared," Directory Defrnois, No. 01/02, pp. 3-19.
    • Christmas Raimon, "Taxation manual gifts associations: the syndrome of expansion?" Associations - The newsletter of the Societe Generale, No. 16, April 2002, pp. 1-6.
    • Writing Editions Francis Lefebvre, "On the taxation of gifts made to cults", Le Monde, 30 November, 1 December 2003.

    Court Notes

    • Bulletin of the Associations and Foundations, No. 31, September 2000, 254.
    • Bulletin of the Associations and Foundations, No. 5, March 2002.
    • Tax Bulletin, December 2000, inf. 1250 and 1251, p. 684.
    • Tax Law Review, 2004, No. 50, pp. 1768-1770.
    • Tax Cases Review, December 2000, pp. 977-980.
    • Tax Cases Review, February 2005, pp. 125-128.
    • La Semaine Juridique Edition Gnrale, No. 46, November 10, 2004, p. 2058.
    • Maurice Christian Shepherd, "Gifts textbooks", Journal of Tax Law, No. 16, 2002, pp. 680-683.
    • Andr Chappert, "Case law - Registration," Directory Defrnois, No. 18/01, 2001, pp. 1041-1047.
    • Andr Chappert, "The tax authorities, the Jehovah's Witnesses and the judge of the tax (continued)" Directory Defrnois, No. 02/05, 2005, pp. 132-148.
    • Xavier Delsol, "Gifts textbooks associations", Juris Associations, No. 256, April 1, 2002, p. 21.
    • Albert Granier, "Association," Law & Heritage, No. 92, April 2001, pp. 115, 116.
    • Lawrence Grosclaude, "Offering or liberality debate on the classification of amounts received by an association," Commercial Law Review, April / June 2005, pp. 372
    • Louis Martin, "Don Manuel" La Semaine Juridique Notaries and Real Estate, No. 1, January 5, 2001, pp. 24, 25.

    Legal Articles various

    Documents Information of Jehovah's Witnesses

    • National Consistory of Jehovah's Witnesses, The financing of worship of Christians Jehovah's Witnesses in France (White Paper), Association of Jehovah's Witnesses ", Louviers, 1999.

    Sources sectes

    See also

    Internal Links

    External Links

    Legal Information Sites

    Official websites of Jehovah's Witnesses



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