The Paris Administrative Court of Appeal decided on 21 June 1994 that receivables for intermediary commissions on negotiating contracts were certain in fact and in amount, as soon as the companies had signed these contracts, and that the rendering of services had to be regarded as completed on such date according to the provisions of Article 38-2 bis of the French General Tax Code. That decision is representative of a rather unclear trend in the case law trend to assimilate the concepts of completion and certainty ( see : Administrative Court of Besanon, 4 November 1994, supra).

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