This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. France’s Supreme Administrative Court (SAC) held in a transfer pricing
Benjamin Conort
Currently Director within the transfer pricing team of Deloitte Société d’Avocats, Benjamin has started my career in Luxembourg.
He is mainly focused on Financial transfer pricing (debt pricing etc.). I also have developed skills in relation to IPs analyses, functional and economic analyses of manufacturers, distributors and service providers.
01 55 61 74 15Benjamin Conort
Deloitte Société d'Avocats
Transfer Pricing
Currently Director within the transfer pricing team of Deloitte Société d’Avocats, Benjamin has started my career in Luxembourg.
He is mainly focused on Financial transfer pricing (debt pricing etc.). I also have developed skills in relation to IPs analyses, functional and economic analyses of manufacturers, distributors and service providers.
France
Case law WB Ambassador: storm warning on intra-group loans?
In its decision of July 7, 2017 (TA Paris, 7 July 2017, n°1607683, WB Ambassador), the TA of Paris retains a strict assessment of the provisions of article 212-I of
Australia lays the foundation of its intra-group financing vision with Chevron case
On April 21st, 2017, the Full Court Federal Court of Australia (FCF) has given a ruling on the deductibility of intercompany interest expense paid by an Australian company (Chevron Australia