Credit Risk Analysis in Intra-Group Financial Transactions: A Tax Controversy Perspective

This article aims to provide an in-depth analysis of credit risk assessment in the context of intra-group financing, from the perspective of French courts.
The credit analysis poses a significant financial challenge. The relevant case law highlights the wide range of issues involved and the high level of rigour required to conduct probative analyses.
Additionally, this case law provides valuable guidance for mitigating tax disputes by incorporating best practices into credit risk analysis.
International Transfer Pricing Journal, IBFD, 21 April 2026, Théophile Trancart