Maturity and Arm's Length Interest Rate:"Time is a greater treasure than one can believe"

The consideration of the maturity of intragroup financing is fundamental to determining an arm’s length interest rate.
It also frequently gives rise to disputes when the tax authorities seek to assert the effective maturity of such financing over the maturity agreed upon by the parties.
Read the article of Théophile Trancart, published in the Revue de droit fiscal on January 9, 2025.