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Article 40 of the 4th Amended Finance Act for 2011 introduces new restrictions to the deduction of financial expenses (i.e., mainly interest) for French corporate income tax purposes in cases where the corresponding debt financings can be deemed contracted in relation to artificial acquisitions of shares
The 4th Amended Finance Act for 2011 introduces a specific anti abuse mechanism designed to defeat the artificial allocation to a French corporation of debt in relation to the acquisition of shares of an entity (other than a real estate company) which is not controlled from France
Implementing the recommendations resulting from the G20 summits held in 2009 in a context of deep international crisis, France has reinforced its set of measures aiming at fighting against tax fraud and evasion with the corrective finance law for 20091
