🇬🇧Personal Use of a Corporate Asset: Benefit in Kind on Jets, Yachts and Villas

An SPV owns the jet, the yacht or the villa, the beneficial owner uses it, and nobody ever issues him an invoice. A tax price for that use arises in all five jurisdictions below; what differs is the size of the bill and the legal label — anything from an employment benefit to a deemed dividend, which carries a different withholding mechanism and different consequences for the company. The spread between the formulas is at its widest here: a 3,000-mile flight on a heavy aircraft costs a US control employee $2,869.68 under SIFL and the full charter rate under the French and Russian rules. Below is how each formula is built, where it breaks, and why the American discount is paid for out of the company's deduction.

The framework

Every jurisdiction answers three independent questions, and the final figure is the sum of all three answers:

• Characterisation — employment benefit, income by virtue of shareholder status, or a hidden distribution of profits
• Valuation — a flat-rate formula, a percentage of the asset's cost, or the full market value of the use
• The corporate side — whether the SPV keeps its deduction for the costs of the asset

United States: SIFL as a built-in discount

The general rule is Treas. Reg. §1.61-21(b)(1): income includes the excess of the fair market value of the benefit over what the recipient paid for it. §1.61-21(b)(2) adds that FMV is the amount a person would have to pay for the benefit in an arm's-length transaction, that “the effect of any special relationship that may exist between the employer and the employee must be disregarded”, and that the employer's own cost does not determine FMV.

The whole section turns on the word “employee”, and that word is broader than an employment contract: §1.61-21(a)(4) extends it to “any person performing services in connection with which a fringe benefit is furnished”. A director, and a shareholder who works for the structure, are inside it. A shareholder who performs no services at all falls outside the fringe benefit regime altogether — his use is analysed under the constructive dividend rules rather than under §1.61-21.

For flights, the general rule yields to an exception. §1.61-21(g)(5) sets out the base aircraft valuation formula: the SIFL cents-per-mile rates for each distance band are multiplied by the aircraft multiple, and the terminal charge is added on top. Each passenger and each leg is valued separately — §1.61-21(g)(3)(ii): “a round-trip is comprised of at least two flights… The value of a flight must be determined on a passenger-by-passenger basis”.

The rates for the first half of 2026 come from Rev. Rul. 2026-8 (I.R.B. 2026-16, p. 812, bulletin dated 13 April 2026): a terminal charge of $54.48; $0.2980 per mile up to 500 miles; $0.2272 for miles 501–1,500; $0.2184 for miles over 1,500. As at 9 August 2026 the rates for the second half of the year have not been published — and even the first-half ruling appeared three and a half months in arrears.

The multiple depends on maximum certified take-off weight and on the passenger's status — §1.61-21(g)(7)(i).

The owner of an SPV lands in the control employee category almost automatically. §1.61-21(g)(8)(i) puts there anyone holding a five-percent or greater equity, capital or profits interest (subparagraph C) and any director (subparagraph D), while the restriction in §1.61-21(g)(8)(ii)(B) — “in no event shall an employee whose compensation is less than $50,000 be a control employee under paragraph (g)(8)(i) (A) or (B) of this section” — applies by its own terms only to grounds (A) and (B), office and pay level. A zero salary therefore leaves the status intact. Family members count equally: §1.61-21(g)(8)(ii)(A) via the definition in section 267(c)(4), and §1.61-21(g)(7)(ii) expressly requires a family member's flight to be valued as though the control employee had taken it. The regulation's own example is a CEO with his spouse and two children on a 12,000 lbs aircraft: “4 × ((300 percent × the applicable SIFL cents-per-mile rates…) plus the applicable terminal charge)”.

Hence the benchmark figure. A 3,000-mile flight on an aircraft over 25,001 lbs for a control employee: (500 × $0.2980 + 1,000 × $0.2272 + 1,500 × $0.2184) × 400% + $54.48 = ($149.00 + $227.20 + $327.60) × 4 + $54.48 = $2,869.68. Chartering a comparable aircraft over that distance is an order of magnitude away.

When SIFL does not apply

SIFL is the employer's option. §1.61-21(c)(2)(ii): “An employee may use a special valuation rule only if the employer uses that rule or the employer does not meet the condition of paragraph (c)(3)(ii)(A) of this section, but one of the other conditions of paragraph (c)(3)(ii) of this section is met”. Outside those conditions the general rule in (b) applies, and §1.61-21(b)(6)(ii) then requires a charter measure: “the amount that an individual would have to pay in an arm's-length transaction to charter the same or a comparable piloted aircraft for that period for the same or a comparable flight”, with an express bar on using the price of a commercial ticket. For an aircraft supplied without a pilot, §1.61-21(b)(7)(ii) gives the cost of leasing a comparable aircraft on comparable terms “in the geographic area in which the aircraft is used”. The same provision governs allocation: the charter cost is spread across everyone on board on the facts and circumstances, but “where one or more employees control the use of the aircraft, the value of the flight shall be allocated solely among such controlling employees, unless a written agreement among all the employees on the flight otherwise allocates the value of such flight”.

The mirror image is the seating capacity rule, §1.61-21(g)(12)(i)(A): where 50 per cent or more of the regular passenger seating capacity is occupied by individuals flying primarily on the employer's business, the flight of everyone else “is deemed to be zero”. It is the only zero inside the SIFL formula itself.

The company pays for the discount

§1.274-10(a)(1) denies any deduction for the costs of using an aircraft for entertainment. The exception in §1.274-10(a)(2)(ii)(A) lifts the bar to the extent the expense is reported as compensation to an employee under §1.61-21. For specified individuals the exception is truncated: §1.274-10(a)(2)(ii)(C) and §1.274-10(c) cap the deduction at the amount included in income plus any reimbursement, “reduced (but not below zero)”. §1.274-9(b)(1) defines a specified individual by cross-reference to section 16(a) of the Securities Exchange Act of 1934 — in practice an officer, a director or a more-than-10% owner — and the test reaches private companies too, applied “as if the taxpayer were an issuer of equity securities referred to in that section”.

The “costs” in §1.274-10(d)(1) sweep in everything: pilot and maintenance-crew salaries, take-off and landing fees, the cost of positioning flights, on-board catering and gifts, hangarage at home and away, management fees, fuel, tyres, maintenance, insurance, registration, inspections, depreciation, interest on debt secured by the aircraft, and payments under leases and charters. The gap between $2,869.68 under SIFL and the real cost of an hour in the air is lost from the deduction in full.

It was not always so. In Sutherland Lumber-Southwest, Inc. v. Commissioner, 114 T.C. 197 (2000), affirmed by the Eighth Circuit at 255 F.3d 495 (2001), a Kansas City lumber business flew its executives on holiday in a 1976 Lear Jet Model 25, imputed SIFL income to them and deducted the full cost of operating the aircraft. The Tax Court found for the taxpayer: §274(e)(2) operates as a complete exception to §274(a)(1), the provision contains no monetary ceiling, and, as the court observed, changing “to the extent that” to “to the extent of” would have imposed one unambiguously. The Eighth Circuit added that on different facts the SIFL amount reported by the employee could exceed the expenses deducted by the employer. Congress closed the gap in the American Jobs Creation Act of 2004 by adding §274(e)(2)(B), from which §1.274-9 and §1.274-10 grew. The deficiencies recited in the decision — $341,631 for 1992 and $119,558 for 1993 — were the product of several adjustments; the opinion gives no separate “aircraft” figure.

Leasing to one's own structure falls outside the saving exception in §1.274-10(d)(2) by definition: that provision speaks of chartering “to an unrelated (as determined under section 267(b) or 707(b)) third-party”. Since 21 February 2024 the IRS has run a dedicated campaign in this area — IR-2024-46 announced “dozens of audits on business aircraft involving personal use”, with Commissioner Danny Werfel putting it plainly: “With expanded resources, IRS work in this area will take off”.

United Kingdom: 20% and a presumption of year-round availability

s.205(2) ITEPA 2003 takes the higher of the annual value of the use of the asset and the actual rent or hire charge paid by those providing the benefit — and adds any additional expense to whichever is greater. Annual value under s.205(3)(b), for everything other than land, is “20% of the market value of the asset at the time when those providing the taxable benefit first applied the asset in the provision of an employment-related benefit”. Land is carved out into s.205(3)(a) and valued at annual rental value, which is why accommodation lives under a separate regime (below). Additional expense under s.205(4) covers expenditure in connection with the provision of the benefit, excluding the cost of acquiring the asset and excluding the rent paid by the provider.

The user's contribution is deducted at the next step, under a separate provision. That provision is s.203(2): the cash equivalent is reduced by any part of the cost “made good by the employee, to the persons providing the benefit, on or before 6 July following the tax year in which it is provided”. The deadline was inserted by F(No.2)A 2017 s.1(13); missing the date destroys the deduction entirely.

s.205(1B) sets the presumption: an asset made available in a tax year is treated as available for private use throughout the year unless two conditions are met at once — the terms on which it is made available prohibited private use at all times in the year, and no private use was in fact made of it. Days can be deducted under s.205A for periods before the first and after the last provision; for days on which, for more than 12 hours, the asset was not in a condition fit for use, was undergoing repair or maintenance, could not lawfully be used, was held by a person with a lien, or was used otherwise than by or at the direction of the user; and for days of exclusively business use. The formula is (U / Y) × A. “The yacht simply sat on its mooring” is not on that list. s.205B caps the aggregate charge across several users of one asset at the annual cost and apportions it “on a just and reasonable basis”. All of this applies from tax year 2017-18 — FA 2017 s.8(5): “The amendments made by this section have effect for the tax year 2017-18 and subsequent tax years”.

The classic worked example is HMRC EIM21633: a yacht bought by the company for £25,000, made available to a director and his family for the whole year, running costs of £2,400, a contribution by the director of £1,500. 20% × £25,000 = £5,000, plus £2,400, less £1,500 — a taxable benefit of £5,900; the £4,500 of interest on the purchase loan stays out of the calculation. The example is historical: the page itself states that it applies to 2016-17 and earlier years and directs the reader to EIM21873 for 2017-18 onwards, the calculation having changed with s.205A and s.205B.

From the same era comes Denny v HMRC [2013] TC02714 — a yacht with a market value of £306,000 and an annual benefit cost of roughly £63,000, which the tribunal apportioned across the weeks of the sailing season: commercial use of 7 / 2 / 1 / 3 weeks against availability to the director of 10 / 15 / 16 / 14 weeks over 1999–2002, producing assessments of £31,058 / £49,588 / £53,294 / £51,882. Occasional commercial charters did not save the position — the tribunal counted weeks of availability. The citation and the figures have been checked against a secondary analysis rather than the primary decision; under the current text, with s.205(1B) in place, the outcome would be worse for the taxpayer.

France: valeur réelle with no ceiling

Art. 82 CGI and BOI-RSA-BASE-20-20 (the version in force from 16 April 2024) define an avantage en nature as “la mise à disposition ou la fourniture par l'employeur à ses salariés d'un bien ou d'un service à titre gratuit ou à un prix inférieur à leur valeur réelle”. §10 of the document ties the tax valuation to the social security valuation: the rules “sont alignées sur celles prévues pour le calcul des cotisations de sécurité sociale”.

There are four flat-rate categories: nourriture (§50), logement (§§120–150, eight income bands and the number of rooms, or the valeur locative cadastrale option), véhicule (§§220–260) and NTIC (§§290–300, a flat 10% of the purchase price or the annual subscription). Yachts, aircraft, works of art and horses are absent from that list and fall into §330: “Les autres avantages en nature sont retenus pour l'assiette de l'impôt sur le revenu, pour leur valeur réelle”. No ceiling, no flat rate.

For the typical beneficial owner this is reinforced by a second layer. §30: benefits granted to persons connected with the business by something other than an employment contract alone — that is, dirigeants within 1°, 2° and 3° of point b of article 80 ter CGI — “sont évalués pour leur montant réel”. The logement flat rate is open to them only where an employment contract and a corporate mandate genuinely coexist (§210); for véhicule an exception is allowed even without an employment contract (§280).

The véhicule rates are currently out of step with themselves. BOFiP in its operative version still gives 9% / 6% of the purchase price and 30% of the annual lease cost. The arrêté of 25 February 2025 raised these to 15% for vehicles under five years old, 10% for older ones and 50% of the annual lease cost, for vehicles made available from 1 February 2025. Because art. 82 CGI aligns the tax rules with the social security rules, the new rates ought logically to apply for income tax as well, but no updated BOFiP commentary existed as at 9 August 2026, and the text of the arrêté on Légifrance is shielded from automated retrieval and was read through a practitioner analysis. The uncertainty is real and worth planning around. These rates have no direct application to yachts or aircraft — they show the direction in which French valuation of benefits in kind is travelling.

Where there is no employment connection at all, art. 111, c CGI takes over: “les rémunérations et avantages occultes sont considérés comme des revenus distribués qu'ils soient ou non prélevés sur les bénéfices”. BOI-RPPM-RCM-10-20-20-40 §20 describes the typical fact pattern as “la prise en charge par la société de dépenses qui ne lui incombent pas normalement et dont elle n'entend pas désigner le ou les bénéficiaires”. A company that fails to name the beneficiary under art. 117 CGI attracts the penalty in art. 1759 CGI: 100% of the sums distributed, reduced to 75% where the company itself declared them. France has no direct equivalent of the American §274: the corporate deduction is attacked through the acte anormal de gestion doctrine and through the same recharacterisation into revenu distribué.

Spain: income by virtue of shareholder status

Art. 42.1 LIRPF describes income in kind as “la utilización, consumo u obtención, para fines particulares, de bienes, derechos o servicios de forma gratuita o por precio inferior al normal de mercado, aun cuando no supongan un gasto real para quien las conceda”. That closing qualification removes the argument that the company would have borne the cost in any event.

The general valuation rule is art. 43.1: “Con carácter general, las rentas en especie se valorarán por su valor normal en el mercado, con las siguientes especialidades”. The special rules follow, and they are addressed to rendimientos del trabajo en especie: accommodation owned by the payer at 10% of the valor catastral, 5% where the cadastral value has been revised in the current or the previous ten periods, subject to a cap of “10 por ciento de las restantes contraprestaciones del trabajo”; and a motor car in use at 20% per annum of the payer's acquisition cost.

For a shareholder those special rules are shut. Art. 25.1.d) LIRPF assigns to rendimientos del capital mobiliario “cualquier otra utilidad, distinta de las anteriores, procedente de una entidad por la condición de socio, accionista, asociado o partícipe”, and art. 41 LIRPF requires related-party transactions to be valued “por su valor normal de mercado”. The text of art. 41 still refers to art. 16 of the former TRLIS; the operative equivalent today is art. 18 of Ley 27/2014. In 2022 the Tribunal Supremo applied that combination to company cars provided to shareholders: the use is taxed as rendimiento del capital mobiliario and valued under art. 41, bypassing the 20% in art. 43. The better-supported citation is the STS of 27 April 2022 in cassation 4793/2020; some sources instead give sentencia 526/2022 of 4 May 2022 (ECLI:ES:TS:2022:1850). The doctrine is stated identically in both accounts, but the judgment should be pulled from CENDOJ before any procedural use.

Most squarely on point for an SPV is TEAC resolución 7312/2024 of 24 September 2025. The fork is this: an asset the company holds in order to exploit it in its ordinary business is valued under the related-party rules of art. 41; an asset acquired specifically for the shareholder's use goes to art. 25.1.d) and art. 43 as “cualquier utilidad derivada de la condición de socio”. The criterion in the TEAC's own words: “habrá que atender a la naturaleza del bien en cuestión y a su relación con las actividades ordinarias de la entidad”. An SPV incorporated to hold the beneficial owner's yacht falls into the second basket almost by definition.

On the corporate side, art. 15 of Ley 27/2014 denies a deduction for expenses that “representen una retribución de los fondos propios” (a), for donativos y liberalidades (e), and for “gastos de actuaciones contrarias al ordenamiento jurídico” (f). The LIS contains no provision aimed at yachts and aircraft specifically — the denial is derived from the interaction with art. 25.1.d) LIRPF.

Russia: full value in the main tax base

Article 211(1) of the Russian Tax Code (as amended by Federal Law No. 418-FZ of 29 November 2024) defines the base as the value of the property “calculated on the basis of prices determined in a manner analogous to that provided for by article 105.3 of this Code”. VAT and excise are included in that value; any partial payment by the taxpayer is excluded. Article 211(2)(2) brings within income in kind “goods received by the taxpayer, work performed in the taxpayer's interest, services rendered in the taxpayer's interest free of charge or with partial payment”.

There is no separate base for income in kind, so it falls into the main tax base through article 210(2.1)(9) and is taxed on the progressive scale in article 224(1) (as amended by Federal Law No. 176-FZ of 12 July 2024): 13% up to RUB 2.4m; RUB 312,000 plus 15% on the excess over RUB 2.4m; RUB 702,000 plus 18% on the excess over RUB 5m; RUB 3,402,000 plus 20% on the excess over RUB 20m; RUB 9,402,000 plus 22% on the excess over RUB 50m. For a non-resident the rate is 30% under article 224(3), subject to a number of carve-outs. A season at a villa, or two months of a yacht at market charter rates, pushes the beneficial owner into the upper bands with no other income at all.

The position of the Ministry of Finance on gratuitous use is set out in letter No. 03-07-11/91447 of 12 November 2021: where an individual receives from an organisation the right to use a vehicle under a gratuitous use agreement, income in kind arises, and the organisation as tax agent must calculate, withhold and pay the tax. The letter deals with VAT, corporate profits tax and personal income tax together; the text has been checked against a legal database rather than against publication on the Ministry's own site.

The Russian position is nonetheless weaker than the British one, for two reasons. Article 211(2)(2) speaks of goods, work and services, and the gratuitous use of a thing is formally none of the three — a well-known point of dispute. No decisions of the Supreme Court or of the commercial cassation courts on personal income tax arising from a beneficial owner's use of his own company's property could be found; the practice consists of administrative guidance. Plan on the footing of the general rule in article 211(1), and litigate in the knowledge that both sides have an argument.

The villa: two taxes for one use

The United Kingdom keeps accommodation outside the 20% rule and inside Chapter 5 of Part 3 ITEPA (ss.97–113). Where the cost of providing the accommodation is £75,000 or less, s.105 applies: the cash equivalent is the rental value for the period less any sum made good, with rental value under s.105(3) being the rent computed by reference to annual value; where the provider itself pays rent exceeding annual value, the actual rent is taken (s.105(4)–(4A)). Above £75,000, s.106 engages, with its four-step calculation and its additional yearly rent, in which ORI is the official rate of interest in force on 6 April of the tax year and C is the cost of providing the accommodation under s.104 or s.107. The £75,000 threshold is not indexed in the statute, so a villa held in an SPV effectively never fits below it.

ORI has stood at 3.75% since 6 April 2025 and remains 3.75% from 6 April 2026; before that it had been held at 2.25%. The Class 1A NIC rate on benefits for 2026-27 is 15%. A villa costing £5m produces an additional yearly rent of roughly £184,000 on top of annual value.

The second layer is ATED. The rates for chargeable period 2026-27:

The return is filed by a company, a partnership with a corporate partner or a collective investment scheme owning a UK dwelling worth more than £500,000. Relief for a qualifying property-rental business is lost if a non-qualifying individual occupies the property, and s.136 Finance Act 2013 defines that person extremely broadly — the list runs as far as “a relative of the spouse or civil partner of a connected person or of a relevant settlor”. The result for a £12m family villa: £151,450 of ATED a year plus an income tax benefit under s.106 on the very same property.

Spain adds its own layer. The imputed income in art. 85.1 LIRPF — 2% of the valor catastral, or 1.1% where it has been revised in the current or the previous ten periods — is addressed to an individual owner and does not apply to a corporate wrapper: there, either art. 25.1.d) with art. 41 applies at the shareholder level on the TEAC's logic, or IRNR does. The parallel to ATED is the Gravamen Especial sobre Bienes Inmuebles de Entidades no Residentes, at 3%, declared on modelo 213. The parallel is weaker than it looks: the GEBI is aimed at entidades residentes en jurisdicciones no cooperativas, making it a narrow anti-offshore instrument next to a broad ATED. The article numbering of arts. 40–45 TRLIRNR is taken from a secondary source and has not been verified against the BOE.

France has no dedicated flat rate for a villa held in an SPV: a dirigeant gets valeur réelle under §30 and §330, and an associé with no employment connection gets revenu distribué under art. 111, c CGI. The United States has no housing analogue to SIFL at all; the general rule in §1.61-21(b)(1)–(2) governs, meaning the market rent for a comparable property.

Renting from your own company

The structure works, and in the United States the regulation itself supplies the benchmark. For a piloted aircraft the reference is the charter of a comparable aircraft on comparable terms under §1.61-21(b)(6)(ii), with the bar on comparing against a commercial ticket price; for a dry lease it is §1.61-21(b)(7)(ii): comparable aircraft, comparable terms, same period, same geographic market. The credit mechanism sits in §1.61-21(b)(1) for the general rule and §1.61-21(c)(2)(ii)(A) for the special rules: the amount determined by the employer under a special valuation rule is reduced by “any amount reimbursed by the employee to the employer”, so a full reimbursement leaves nothing to include. The condition is that the employer uses the same method. The often-quoted sentence “if an employee reimburses an employer… no amount is includable” sits in §1.61-21(c)(2)(i), and that paragraph states on its face that it applies to benefits provided before 1 January 1993; the citation to use today is (c)(2)(ii)(A).

How the structure breaks depends on the jurisdiction. In the United States it is the self-rental rule, Treas. Reg. §1.469-2(f)(6): net income from renting property to an activity in which the taxpayer materially participates “is treated as not from a passive activity”, while a loss on the same rental stays passive. The owner ends up with taxable income and nothing to shelter it with. In France, a below-market rate for a dirigeant or an associé is an avantage occulte under art. 111, c CGI and revenu distribué whether or not there are profits, plus the art. 1759 penalty if the beneficiary is not named. In Spain, TEAC 7312/2024 sends an asset bought for the shareholder's use into art. 25.1.d) regardless of the contract, and the rate must survive the valor normal de mercado test in art. 41 LIRPF. In Russia, the reference in article 211(1) to the article 105.3 methodology means the difference between the contractual and the market rate is taxed as income in kind in any event.

The minimum documentary set follows directly from the rules: a written agreement at a supportable rate with comparable quotations from the same period and market; actual payment before the reporting date, and in the United Kingdom before 6 July following the tax year under s.203(2); per-flight and per-day logs to separate business from private periods; and, in the United Kingdom, a contractual prohibition on private use coupled with no private use in fact, failing which the s.205(1B) presumption bites.

Popular, and it ends badly

Sources

• 26 CFR §1.61-21 — general FMV rule, the extended definition of “employee” in (a)(4), the SIFL formula, aircraft multiples, the control employee definition, charter and dry-lease valuation, the seating capacity rule, and the reimbursement mechanics in (c)(2)
• Rev. Rul. 2026-8, I.R.B. 2026-16 — SIFL rates for 1 January to 30 June 2026, terminal charge $54.48, p. 812
• NBAA — SIFL Rates — confirmation that no rates have been published for the second half of 2026
• 26 CFR §1.274-10 — disallowance for entertainment flights, the cap for specified individuals, the composition of expenses including depreciation, the unrelated third-party exception
• 26 CFR §1.274-9 — specified individual defined by reference to section 16(a) of the Securities Exchange Act of 1934
• Sutherland Lumber-Southwest, 114 T.C. 197 (2000) and 255 F.3d 495 (8th Cir. 2001) — full-cost deduction against SIFL before the 2004 amendment; 1976 Lear Jet Model 25, deficiencies of $341,631 and $119,558
• IRS IR-2024-46 — the audit campaign on personal use of corporate aircraft, 21 February 2024
• 26 CFR §1.469-2 — the self-rental rule, §1.469-2(f)(6)
• ITEPA 2003, s.205 — higher of, 20% of market value at first provision, additional expense, the s.205(1B) presumption
• ITEPA 2003, s.203 — deduction for the user's contribution and the 6 July deadline
• ITEPA 2003, s.205A and s.205B — the (U / Y) × A formula, the grounds of unavailability, the cap where there are several users
• Finance Act 2017, s.8 — the new text applies from 2017-18
• HMRC EIM21633 — the historical yacht computation, £25,000 → £5,900; current guidance at EIM21873
• ITEPA 2003, s.105 and s.106 — accommodation below and above £75,000, additional yearly rent via ORI
• HMRC — beneficial loan arrangements, official rates — ORI at 3.75% from 6 April 2025 and from 6 April 2026
• HMRC — rates and thresholds for employers 2026 to 2027 — Class 1A NIC at 15%
• ATED — the basics, gov.uk — the 2026-27 rates and the persons chargeable
• Finance Act 2013, s.136 — non-qualifying individual defined as far as relatives of the spouse of a connected person
• BOI-RSA-BASE-20-20 — art. 82 CGI, alignment with the social security valuation, montant réel for dirigeants (§30), the four flat-rate categories, §330 valeur réelle
• Village de la Justice — arrêté of 25 February 2025 — new véhicule flat rates of 15% / 10% / 50% from 1 February 2025; the primary text on Légifrance is not reachable for automated verification
• BOI-RPPM-RCM-10-20-20-40 — art. 111, c CGI, avantages occultes as revenus distribués, the art. 1759 penalty where the beneficiary is not named
• Ley 35/2006 del IRPF — art. 41, art. 42.1, art. 43.1, art. 25.1.d), art. 85.1
• Ley 27/2014 del Impuesto sobre Sociedades — art. 15, non-deductible expenses
• TEAC resolución 7312/2024 of 24.09.2025 — analysis and commentary by Garrido — the fork between art. 41 and art. 25.1.d)
• Tribunal Supremo 2022, analysis by fiscal-impuestos and Iberley — doctrine on shareholders' cars; the sources disagree on the judgment's reference
• Article 211, Russian Tax Code — income in kind and the reference to art. 105.3, as amended by Law 418-FZ of 29.11.2024
• Article 224, Russian Tax Code — the progressive scale as amended by Law 176-FZ of 12.07.2024
• Article 210, Russian Tax Code — the main tax base, art. 210(2.1)(9)
• Ministry of Finance letter No. 03-07-11/91447 of 12.11.2021 — personal income tax on gratuitous use of an organisation's vehicle
• Gravamen Especial sobre Bienes Inmuebles de Entidades no Residentes — the 3% rate, modelo 213, application to entidades residentes en jurisdicciones no cooperativas
• [Rossmartin — Denny v HMRC [2013] TC02714](https://www.rossmartin.co.uk/sme-tax-news/1104-director-company-improvements-to-property-and-yacht-benefit) — the yacht figures for 1999–2002