France - Reorganization of Intra-Group Support Functions: A Transfer of Profit?
- P. Escaut; E. Bonneaud
- International Transfer Pricing Journal, 2013 (Volume 20), No 5
- 21 August 2013
The authors consider a recent court case in France on the tax treatment of the intra-group transfer of cash pooling activities, as well as possible future applications of the court’s decision.