Renaud Jouffroy Xavier Etienne To date, third party or bank debt has remained outside the scope of French thin capitalisation rules, even when this debt has been guaranteed by a party connected to the borrower. This made France a very attractive jurisdiction in which to raise debt. However, Finance Act 2011, which was recently passed by parliament, has brought France more in line with other countries by removing the thin cap exemption for guaranteed third party debt (such as bank debt).
March 01 2011