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French Supreme Administrative Court Rules on Arm's Length Adjustments for Interest-Free Loans

|Approved Changes|France
France

The French Supreme Administrative Court (Conseil d'Etat) issued a decision on 20 December 2024 concerning arm's length adjustments for interest-free loans from a parent company to its subsidiaries. The case involved a French company, Fibusa, which provided interest-free loans to its Romanian subsidiaries in the year 2011 to 2014. Following an audit, the tax authorities determined that this was…

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