The French Tax Authorities recently gave some precisions concerning the following problems linked to the French Tax Consolidation Regime:
- the updating of the losses and deemed deferred depreciations is not forbidden, however the implementation of such a technique requires an adaptation of the rules of common right.
- moreover, the forgivenesses of debts with a betterment clause granted between companies of the same tax consolidated group are subject to a differentiated treatment depending on the date of the forgiveness of debt and that of the betterment clause.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be brought about your specific circumstances.
For additional information contact Claire Acard on 33/(1)/55 61 10 10, Lionel Benant on 33/184.108.40.206 or Joel Fischer on 33/220.127.116.11 or enter text search: 'ARCHIBALD ANDERSEN' and 'Business Monitor'. The members of ARCHIBALD ANDERSEN Association d'Avocats (S.G. Archibald and Arthur Andersen International) are registered with the Hauts-de-Seine Bar and the Lyon Bar.