The Resource French branch of foreign company must charge interest to its head office in consideration for cash advances provided to the latter

French branch of foreign company must charge interest to its head office in consideration for cash advances provided to the latter

Label
French branch of foreign company must charge interest to its head office in consideration for cash advances provided to the latter
Title
French branch of foreign company must charge interest to its head office in consideration for cash advances provided to the latter
Creator
Subject
Language
  • eng
  • eng
Summary
This note examines a ground-breaking decision of the French Supreme Administrative Court (Sodirep Textiles SA-NV) 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
Citation source
In: European taxation. - Amsterdam. - Vol. 56 (2016),
http://library.link/vocab/creatorName
  • Escaut, P
  • Glon, G
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • case law
  • transfer pricing
  • intercompany loan
  • branch
  • head office
Label
French branch of foreign company must charge interest to its head office in consideration for cash advances provided to the latter
Instantiates
Publication
Note
20160511
Other control number
et_2016_04_fr_1.html
Label
French branch of foreign company must charge interest to its head office in consideration for cash advances provided to the latter
Publication
Note
20160511
Other control number
et_2016_04_fr_1.html

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