French Tax Aspects of Cross-Border Restructurings

Journal
France; International
Bulletin for International Taxation 2011 (Volume 65), No. 4/5
International restructurings have increased exponentially in the current globalized business world. Consequently, the authors consider various key aspects of such restructurings with regard to France, including OECD guidance on the issue, the recharacterization of transactions, challenges to pre- and post-restructuring transactions, and relevant financing matters.