The Court of Versailles decided on July 5, 1994 that Article 39-1-3 of the French General Tax Code, reducing the deduction of interests granted by a company to its shareholders, should be strictly interpreted.
As a consequence, the exchange loss linked to a currency loan must not be taken into account for the assessment of this reduction.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances. For additional information contact Claire Acard on 33/(1)/55 61 10 10 or Lionel Benant on 33/78.63.72.35. 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.
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