I may be wrong but I seem to remember the French categorized JWs as a "dangerous sect" and not a real religion and therefore not subject to the tax exemption.
But, I've also just read that the French government is saying that the donations were actually used to "purchase" literature and therefore subject to tax. In other words, the WTS is a publishing company that should be taxed as other publishing companies.
If that's the argument, I can see this sticking. The fact is that most of the donations are used for the purpose of literature production. Think about it, the number of WT and Awakes each month, KMs, books, bibles, ect. If they were to spin off the literature production operation into a for profit entity, I would guess they would need at least 75% or more of the total revenues to support it.
Without literature production, Bethel expenses would be really low. You would really only need a small office complex. DOs, COs and to some extent special pioneers are the only real clergy expenses. Of course, many Bethel heavies would also be included but still the number is pretty low. Plus, if you moved many of them to the for profit publishing company, there would be only a few left.
Interesting problem. If the WTS loses this case, it will have a profound impact on how they run their business going forward. The Swaggart case here in the US had a drastic impact on their cashflow. I can see this case having just as much of an impact. Couple that with the Spainish government making them pay into social security (which I'd bet the rest of the EU may look into) and the poor economy and you have a recipe for major operational overhaul.