Interest rate on loans from affiliated entities
The french tax authorities published online 8 practical notes to clarifiy, with the use of concrete examples, how to justify of the interest rate applicable pursuant to article 212-I-a of the French tax code and to outline examples of good practices. These notes relate to:
- the dialectic of the evidence;
- the applicable means of proof;
- comparability – publications of rating agencies and credit risk;
- comparability – cases of adjustments that improve the reliability of a comparable;
- comparability – existence of multiple and substantial differences;
- comparability – multiple borrower bank loan agreement;
- comparability – «mirror» loans;
- comparability – bond capital market.
