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France - French Branch of Foreign Company Must Charge Interest to Its Head Office in Consideration for Cash Advances Provided to the Latter

Country:
France
Author:
P. Escaut; G. Glon
Issue:
European Taxation, 2016 (Volume 56), No 4
Published:
7 March 2016
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.
 
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