Tax Implications of Transferring an Intragroup Loan

At first glance, the transfer of intragroup financing may appear to be a transaction with negligible stakes.
However, in a financial environment characterized by high volatility and increased scrutiny by French tax authorities of intragroup financial transactions, it requires particular attention to manage the tax implications, secure the fair market value, and thus prevent the risk of tax reassessment.
Read the article, co-authored by Théophile Trancart and Florian Tumoine, published in La Lettre du Trésorier (December 2025). This journal is published by the French Association of Corporate Treasurers (AFTE).