OrbitaxFrench Court of Appeals decision on debt waivers granted to branches of foreign subsidiary by French parent company published
|Treaty Development|France-Australia-Hong Kong-Singapore
In a recently published decision of 11 March 2005 (SA Guerlain, No. 01PA01206), the Court of Appeals of Paris held that the debt waivers granted by a French parent company to two branches of its 99.9%-owned Hong Kong subsidiary constituted a transfer of profits under Art. 57 of the French Tax Code (Code Général des Impôts (CGI)). The details of the decision are summarized below.
(a) Bac…
Continue Reading
