Nicolas Vergnet is a doctor of law and Assistant Professor in public law at the University Panthéon-Assas (Paris 2). In parallel to his teaching activities, he works as a tax consultant in the Tax and Structuring Department of the Mayer Brown law firm. His doctoral thesis on “Value creation and allocation in international tax law” has been awarded the Mitchell B. Carroll Prize of the International Fiscal Association. He is the author of numerous articles and research works in major French publications including Les Echos, Revue de Droit Fiscal, and CF News Immo & Infra.
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1. Introduction For several years now, the French tax administration has been paying growing attention to intragroup financing strategies. Numerous litigations...