Lawyers
An experienced team with a holistic approach to your intragroup financing needs
Théophile Trancart
Théophile Trancart is the founder of Cohérence.
He advises both listed and private companies in French and international contexts, supporting them during transactions as well as in tax audit or controversies.
He regularly publishes articles in authoritative French and international journals.
Before founding Cohérence, he began his career in the tax department of an international corporate group, then joined a boutique law firm specializing in tax and transfer pricing, where he worked closely with former members of the French tax authorities.
Publications and press
● Intra-group Financial Guarantees: Remuneration is the Cornerstone of Security, La Lettre du trésorier, June 2026, co-authored by Théophile Trancart and Teddy Ben
● Credit Risk Analysis in Intra-Group Financial Transactions: A Tax Controversy Perspective, International Transfer Pricing Journal, IBFD, 21 April 2026 ● Tax Implications of Transferring an Intragroup Loan, La Lettre du Trésorier, December 2025, co-authored by Théophile Trancart and Florian Tumoine
● Abnormality in Light of Market Practice, Revue de droit fiscal, LexisNexis, May 2025
● Maturity and Arm's Length Interest Rate: "Time is a greater treasure than one can believe", Revue de droit fiscal, LexisNexis, January 2025
● SAP Case: Assessing the Interest of a Cash Pool Participant in a Cash Pooling Agreement, Revue de droit fiscal, LexisNexis, June 2024
● Assessing Arm’s Length Guarantee Fee: Insights from the Crédit Industriel et Commercial Case, International Transfer Pricing Journal, IBFD, April 2024
● Subordination and Arm's Length Principle: When Financing is Layered, Revue de droit fiscal, LexisNexis, September 2023, co-author with Teddy Ben
● Former Anti-Hybrid Regime, Interest Rates Paid Between Related Entities, and Abnormal Act of Management: Where the Deduction of Financial Charges Disappears, Revue de droit fiscal, LexisNexis, May 2023
● Interest Free Loans: How to Determine the Amount of the Adjustment? Revue de droit fiscal and Semaine juridique - Entreprise et Affaires, LexisNexis, March 2023
● Rising Interest Rates and Their Implications for Intra-Group Financing, interview, Daf Mag, November 2022
● SAP Case: When to Assess the Interest of a Cash Pool Participant in Centralized Cash Management? Revue de droit fiscal and Semaine juridique - Entreprise et Affaires, LexisNexis, October 2022
● A Kaleidoscope of Financial Guarantees: Reflections on the Arm’s Length Principle, Revue de droit fiscal, LexisNexis, September 2022
● Implicit Support: From Unanimous Recognition to Practical Questions, Revue de droit fiscal, LexisNexis, June 2022
● Hard-to-Value Intangibles: A Journey Through the Time Machine of Value Creation,"Revue de droit fiscal, LexisNexis, March 2019, co-authorAssociations
● Member of the Institut des Avocats Conseils Fiscaux● Member of the l'International Fiscal Association
Industry
● Gaming● Software● Packaging● Transport and Logistics● Consulting Firm● Telecommunications● Media and Communications● Web Hosting and Cloud Computing● Event Management● Higher Education● Chemistry● Food & Beverage (Agri‑food)● Food and Facilities management● Consumer Goods● Luxury Industry
Education
● Master's degree in Corporate Finance and Financial Engineering - Conservatoire National des Arts et Métiers● Executive Program in Transfer Pricing - University of Lausanne● CAPA (French Bar exam) - Paris Bar School● Master's degree in Tax and Customs Law - University of Cergy-Pontoise
Languages
● French● English● Spanish