French Branch of Foreign Company Must Charge Interest to Its Head Office in Consideration for Cash Advances Provided to the Latter
Journal
Country
France
Published Date
Issue
European Taxation 2016 (Volume 56), No. 4
Document
This note examines a ground-breaking decision of the French Supreme Administrative Court that held that a French branch of a foreign company must, under transfer pricing rules, charge interest to its foreign head office in relation to internal cash advances provided to the latter despite the absence of a separate legal personality.