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The current rules to combat thin capitalisation, stemming from the Finance Act for 2006 and applicable since 1 January 2007, have been significantly tightened through an amendment adopted as part of the discussion of the Finance Bill for 2011 applicable to financial years ending 31 December 2010. These rules, which until now limited the tax deductibility of interest paid to affiliated companies, will now apply, under certain conditions, to loans granted by third parties…

Bertrand Lacombe

Lawyer at the Court, Lacombe Avocats

Experts de premier plan en droit fiscal