Thin capitalization : recent guidance from tax authorities

Journal
Author
Douvier, P-J.; Lordkipanidze, X.
Country
France
Published Date
Issue
International Transfer Pricing Journal 2008 (Volume 15), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

Criticized by practitioners, struck down by court as discriminatory and judged by the French tax authorities as having too narrow a scope of application, the thin capitalization rules under the French Tax Code were amended by the Finance Act for 2006. This article considers the 2007 Statement of Practice issued by the tax authorities in response to issues raised by the amended thin capitalization rules.