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Consolidated Financial Statements as of December 31, 2015

Notes to the Consolidated Financial Statements

Disputes and legal proceedings

9.2

In the normal course of its operations in around a dozen different countries, the Group is involved in tax, employee-related and commercial

disputes and legal proceedings.

Tax reassessments

9.2.1

In 2004, however, the French tax authorities reversed their decision

and instructed the Group to repay the refunded amounts for the years

2001 to 2003, totaling 145 million euros. Although this amount was

Certain Group companies have been or are currently the subject of tax

paid by Carrefour in 2012, the Group has contested the validity of the

audits conducted by their local tax authorities.

claim and the case is currently pending before the tax courts.

In Brazil, tax audits are in progress covering, in particular, the tax on

Employee-related disputes

9.2.2

the distribution of goods and services (ICMS), related tax credits

(determination of the amounts claimable and documentation of the

claims), and federal contributions to the social integration program

As a major employer, the Group is regularly involved in disputes with

and to the financing of the social security system (Pis-Cofins). The

current or former employees.

Group has challenged most of the reassessments, particularly the

constitutionality of certain legislative provisions on which they are From time to time, disputes may also arise with a large group of

based. The estimated risk in each case is reviewed regularly with current or former employees. In Brazil, many former employees have

Carrefour Brazil’s advisors and an appropriate provision is recorded.

initiated legal proceedings against the Group, claiming overtime pay

that they allege is due to them.

In Argentina, in previous years the tax authorities have challenged

Carrefour's omission of certain categories of supplier rebates from the

Legal and commercial disputes

9.2.3

basis for calculating sales tax. Carrefour contested the tax authorities'

interpretation but nonetheless recorded a provision in prior years for

The Group is subject to regular audits by the authorities responsible for

the estimated risk, as determined jointly with its local tax advisors. The

overseeing compliance with the laws applicable to the retail industry

dispute concerning the proposed reassessments was settled in 2015,

and by the competition authorities. Disputes may also arise with

with no material impact on the Consolidated Financial Statements for

suppliers as a result of differing interpretations of legal or contractual

the year.

provisions.

In France, up until 2003, Carrefour paid a rendering levy (

taxe

On October

1, 2012, a report on the price increases applied by major

d’équarrissage

) on its meat purchases. In 2003, the Court of Justice of

retailers for "household and personal care" products was handed to the

the European Union ruled that this levy, which was paid over by the

Belgian competition authorities. The report alleges that between 2002

French State to abattoirs, constituted state aid awarded in breach of

and 2007, the leading retailers coordinated price increases for these

EU rules. As a result of this ruling, the rendering levy paid for the years

products with the help of the products' suppliers. In relation to this

1997 to 2003 was refunded to the Group.

report, Carrefour was obliged to pay a fine to the Belgian competition

authorities in June 2015.

Contingent liabilities

9.3

To the best of the Group's knowledge, there are no contingent liabilities that may be considered as being likely to have a material impact on the

Group’s results, financial position, assets and liabilities or business.

2015 REGISTRATION DOCUMENT

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