The French Finance Law of 2002 significantly amended section 209II of the French Tax Code (FTC) relating to the transfer of NOLs (net operating losses) in corporate restructuring (mergers, spin-offs, split-offs and contributions of business lines). French tax authorities issued administrative guidelines on this new provision (August 21 2002, 13 D-2-02) in which they notably made comments upon cross-border transactions.
November 01 2002