Tax Implications of Transferring an Intragroup Loanby Théophile Trancart and Florian Tumoine, published in the December 2025 issue of La Lettre du trésorier
To celebrate the beginning of this new year, Cohérence has partnered with artist Guillaume Le Méliner to create a work specially designed for the occasion.
Maturity and Arm's Length Interest Rate: "Time is a greater treasure than one can believe"by Théophile Trancart, published in Revue de droit fiscal, January 9, 2025
SAP Case: Assessing the Interest of a Cash Pool Participant in a Cash Pooling Agreementby Théophile Trancart, published in Revue de droit fiscal, June 6, 2024
Assessing Arm’s Length Guarantee Fee: Insights from the Crédit Industriel et Commercial CaseInternational Transfer Pricing Journal, IBFD, 11 April 2024, Théophile Trancart
Former Anti-Hybrid Regime, Interest Rates Paid Between Related Entities, and Abnormal Act of Management: Where the Deduction of Financial Charges Disappearsby Théophile Trancart, published in Revue de droit fiscal, May 25, 2023
SAP Case: When to Assess the Interest of a Cash Pool Participant in Centralized Cash Management? by Théophile Trancart, published in Revue de droit fiscal, October 13, 2022
A Kaleidoscope of Financial Guarantees: Reflections on the Arm’s Length Principle by Théophile Trancart, published in Revue de droit fiscal, September 15, 2022