Subordination and Arm's Length Principle:When Financing is Layered

Subordination, a widely used technique in corporate financing, leads to an increased interest rate corresponding to the higher level of risk borne by subordinated creditors.
However, within the context of intragroup financial relations, this hierarchy—of both financing and remuneration—remains a contentious issue with the French tax authorities.
Read the article of Théophile Trancart and Teddy Ben, published in the Revue de droit fiscal on September 28, 2023