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Thin capitalization – Tax authorities extend safe haven measure

|Approved Changes| France
 France

On 6 July 2010, the French tax authorities issued a Ministerial Reply (Rép. Bouvard, AN, No. 67614), in response to a question addressed by a member of the lower chamber of the parliament (Assemblée Nationale), regarding the extension of the domestic thin capitalization rules' safe haven measure.

(a) Background. Under the French General Tax Code, the deductibility …

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