Abstract

This note examines a ground-breaking decision of the French Supreme Administrative Court 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.

Full Text
Published version (Free)

Talk to us

Join us for a 30 min session where you can share your feedback and ask us any queries you have

Schedule a call