On 30 November 2012, the Tax Administrative Guideline (BOI-IS-30-50-10-20121130) clarified the regime of deductibility of financial charges expenses related to the acquisition of equity securities.
Under article 209 IX of the French Tax Code, the deductibility of financial expenses linked to the acquisition of equity securities realized as from 1 January 2012 are limited. In the case of acquisition of equity securities, financial expenses are only deductible if the purchaser can demonstr…