Thin capitalization rules and the non-discrimination principle

Journal
Author
Gouthière, B.
Country
France
Published Date
Issue
European Taxation 2002 (Volume 42), No. 4
FormatPDF
EUR
45
| USD
50 (VAT excl.)

The decision of the Court of Appeal of Nantes is discussed wherein it was held that interest paid by a French company to its Austrian parent company could not be allowed as a deduction for French tax purposes, insofar as the interst was paid to a non-resident parent company.