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France Issues Final Guidelines on Interest Deduction Limitations for Related Party Loans

|Approved Changes|France
France

French tax authorities issued final guidelines on 5 August 2014 for rules enacted earlier this year that limit interest deductions on loans between related parties. While the rules were initially targeted at hybrid instruments, under the guidance they can apply to any debt arrangement where the interest income is not taxed or taxed at low rates.

The final guidelines are similar to draft guide…

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