France: Introduction of New Anti-Abuse Rules on the Tax Deductibility of Interest and other Financing Expenses

Orrick, Herrington & Sutcliffe LLP
Contact

Until recently, private-equity investment funds and international corporate groups investing in France enjoyed a very favorable tax environment, including inter alia the benefit of both EU Directives and the double tax treaties signed by France, as well as the ability generally to “push down” debt incurred in connection with their acquisitions through the combination of (i) the tax consolidation regime, (ii) the 95% exemption of dividends from subsidiaries, (iii) the full deductibility of interest and other financing expenses, subject thin capitalization and arm’s length interest rate requirements, and (iv) the unlimited carry-forward of losses.

Although still competitive with other jurisdictions, the French tax environment is becoming less favorable as the pressure grows on France’s budget.

Please see full Article below for further information.

Please see full publication below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Orrick, Herrington & Sutcliffe LLP | Attorney Advertising

Written by:

Orrick, Herrington & Sutcliffe LLP
Contact
more
less

Orrick, Herrington & Sutcliffe LLP on:

Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide
- hide