interest, arrears and other obligations, debts and deposits, fees to transfer or grant of licenses, patents for inventions, trademarks, processes or formulas, manufacturing and other similar rights or remuneration for services, paid or payable by a natural or legal person resident or established in France with natural or legal persons who are domiciled or established in a foreign State or territory outside France and are subject to preferential tax treatment, are allowed as deductible expenses for the preparation of tax only if the debtor demonstrates that expenditures reflect actual operations and they do not show an abnormal or exaggerated.
For the purposes of the first paragraph, persons are regarded as subject to a preferential tax regime in the state or territory in question if they are not taxed or if they are subject to income taxes or whose income is less than the amount of over half that of the tax on profits or income from which they were accountable in terms of common law in France, if they were resident or established.
The first paragraph also apply to any payment made to an account held in a financial institution established in a state or territory listed in that paragraph.
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