Legal & Tax Training
Mastering the Deduction Mechanisms for Financial Expenses within Tax Consolidation
Key information
Prerequisites
- Strong knowledge of corporate taxation
- A solid understanding of the tax consolidation regime (equivalent level to our training ‘The Fundamentals of Tax Consolidation’)
Target Audience
- Corporate tax specialists
- Consolidation managers and accounting managers
- Auditors and management controllers
- Chartered accountants
- Anyone involved in group taxation matters
Operational and training objectives
- Understand the general principles governing the deduction of financial expenses
- Master the rules applicable to the deduction of financial expenses between related companies (shareholder current accounts and transfer pricing principles)
- Understand the impact of anti-hybrid measures (ATAD 2 Directive)
- Master the tax deductibility rules resulting from ATAD 1 Directive (thin capitalization, tax EBITDA, definition of financial income and expenses, safeguard clauses at the boundaries of tax consolidation, calculation of deferred interest and unused deduction capacity)
- Understand the impact of the Charasse amendment
- Reporting and documentation aspects
Mastering the Deduction Mechanisms for Financial Expenses within Tax Consolidation
Our training course ‘Deduction of Financial Expenses within Tax Consolidation’ provides an in-depth presentation of the rules governing the deduction of financial expenses within a tax consolidated group. This deduction is subject to a wide range of rules, the interaction of which may prove complex in the context of tax consolidation (e.g. limitation of deductible interest rates, regulations arising from ATAD 1 Directive, anti-hybrid measures, and mechanisms specific to tax consolidation).
Educational and technical resources
Educational resources
Pedagogical processes
- Training with theoretical contributions
- Discussions on trainees' experience and exchanges with consultant trainers
Evaluation methods
- Assessments of acquired knowledge through questionnaires at the end of each module
- Certification preparation (mock exam on day 3)
- Self-assessment of the trainee through the needs analysis form sent before the training
- Immediate feedback at the end of the training
Technical resources
- Digital training materials in English
In-person
- Training room equipped with a whiteboard and projector
- Provision of supplies (pens, notepads, ...)
Remote
- Access to training via Teams application
Supervision means
- Lawyers with expertise in direct tax and tax consolidation matters and accountants
- DPO competency certification awarded by AFNOR under delegation from the CNIL