{"id":8865,"date":"2026-06-02T19:46:24","date_gmt":"2026-06-02T17:46:24","guid":{"rendered":"https:\/\/www.altertax-avocats.com\/management-fees-abnormal-act-avoid-the-risks\/"},"modified":"2026-06-29T12:10:47","modified_gmt":"2026-06-29T10:10:47","slug":"management-fees-abnormal-act-avoid-the-risks","status":"publish","type":"post","link":"https:\/\/www.altertax-avocats.com\/en\/management-fees-abnormal-act-avoid-the-risks\/","title":{"rendered":"Management fees abnormal act: avoid the risks"},"content":{"rendered":"\n \n

Management Fees and Abnormal Management Acts: Tax Risks and Prevention<\/h1>\n \n
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Management fees are a common practice within groups of companies, providing remuneration for services rendered between related entities. However, the tax authorities rigorously examine these agreements to detect any abnormal acts of management likely to call into question the deductibility of the corresponding expenses. You need to understand the qualification criteria and the risks involved to secure your intra-group agreements<\/a>. <\/p>

What are management fees?<\/h2>

An abnormal act of management refers to a management decision that places the company outside normal operating conditions. In the context of management fees, this is the case when you pay remuneration without any effective consideration, or when the amount invoiced clearly exceeds the market value of the services rendered. This requalification leads to the reintegration of the sums in the taxable income of the payer company, with the application of late payment interest and potential penalties. <\/p>

Criteria for qualifying as an abnormal act of management<\/h2>

Lack of real consideration<\/h3>

The first analysis criterion concerns the reality of the services invoiced. Demonstrate the reality and usefulness of the services rendered to the beneficiary company. A rigorous management fees agreement<\/a> must include the following elements: <\/p>