The Lyon Administrative Court of Appeal (28 September, 1994) upheld the method of calculating employment tax payments utilized by the French Tax authorities (Adm. doctrine 5 L 1522, nø 2, 2 July, 1990). Contrary to the appellant's position, the ratio of sales revenues not subject to VAT to total sales revenues ("contreprorata") must be applied directly to the tax, calculated on each level of salary according to the progressive rates provided by article 231-2 bis of the French General Tax Code, rather than on the amount of the remuneration prior to the calculation of the tax.

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