Managing intragroup financing

Market conditions are evolving, and the increasing demands from French tax authorities require close attention when it comes to structuring and compensating your intercompany financing arrangements.
We assist in facilitating and securing your intragroup financial transactions, particularly in relation to loans, cash pooling, and financial guarantees.
We adopt a comprehensive approach, incorporating the definition of the most suitable financing terms and conditions, financial analysis, and the determination of arm’s length interest rates, as well as assessing tax implications, drafting agreements, and producing supporting analyses for transfer pricing documentation.
We also provide assistance throughout the life cycle of financing, including during the transfer of these financing arrangements.
Our team possesses proven expertise, an excellent understanding of the challenges inherent in corporate financing, and an in-depth knowledge of the positions held by French tax authorities and courts.