Intragroup stablecoin loans
A French subsidiary receives one million dollar-pegged tokens from its overseas parent. The blockchain records the transfer. It does not establish what the subsidiary must repay, when repayment is due or why the interest rate is supportable.
Those questions belong in the financing file before funds move. A dollar-denominated obligation settled through tokens exposes the parties differently from an obligation to return a fixed number of tokens. That distinction affects both the credit analysis and the search for comparable financing.
Establish the obligation before pricing it
The OECD framework and French guidance require analysis of the economic characteristics of the financing, including repayment capacity, term, contractual conditions, risks and the parties' realistic alternatives. Group membership also matters to the credit assessment. [S1, S2]
BECTRA's transaction sheet adds the settlement arrangements. It records the denomination of the liability, the asset delivered, conversion and substitution terms, custody responsibilities and the allocation of transaction costs. It also identifies what happens if the token loses parity, an address is frozen or access is lost.
This is a BECTRA analytical tool, rather than a statutory checklist of mandatory clauses. The signed contract must be assessed alongside the decisions, resources and actual flows. The name given to a transfer is insufficient evidence of its economic substance.
A French borrower needs two lines of analysis
One file supports the remuneration of the intragroup transaction. A separate review addresses French interest deductibility.
French guidance dated 15 July 2026 explains the mechanism under CGI article 212, I-a: above the reference rate, the borrower may support the rate available from an independent financier under analogous conditions. The evidence must relate to the financing's date and characteristics. [S3]
An arm's-length rate therefore does not, on its own, establish the final deductibility of every interest expense. Other limitations and the company's circumstances require separate consideration. This article does not calculate a French tax ceiling.
For the French finance team, the practical output is a cash-flow forecast, evidence of accessible financing, the proposed loan terms and an explanation of material differences. A screenshot showing a crypto protocol's yield is not sufficient evidence of the rate that an independent lender would offer this borrower.
Worked example: one transfer, two different exposures
This is a fictional case. All rates and costs are illustrative assumptions, not market quotations or a benchmarking conclusion.
A French subsidiary is purchasing equipment invoiced in dollars. Its parent delivers 1,000,000 tokens, each initially valued at USD1. The funding lasts 180 days on an assumed 360-day interest basis. The contract creates a USD1,000,000 liability repayable in dollars; the token is the delivery mechanism.
Intragroup interest — 1,000,000 × 6% × 180/360 : USD30,000
Initial conversion — Assumed cost borne by the subsidiary : USD1,500
Custody and transfers — Assumed cost over the period : USD500
Cash outflows included in this illustration — Interest plus the above costs : USD32,000
Management can compare this USD32,000 with a documented bank alternative having relevant maturity and terms. That total-cost comparison informs the treasury decision. It does not by itself demonstrate that 6% is an arm's-length interest rate.
Now change the contract: the subsidiary must return 1,000,000 tokens. If each token trades at USD0.98 at maturity, their market value is USD980,000 before interest and fees. Under the original dollar obligation, the principal remains USD1,000,000. The same initial transfer can create materially different repayment exposures.
The hypothetical USD20,000 difference belongs in the contractual risk analysis. It is neither an established tax benefit nor a certain loss. The file must explain who bears parity risk, whether a replacement asset can be required and how an incident would affect performance of the obligation.
Separate credit remuneration from settlement services
BECTRA's proposed workflow is to build the financing sheet, identify relevant comparable information, explain adjustments and isolate the settlement circuit's costs. Credit remuneration, custody charges and treasury services should each be traceable to the relevant activity or risk.
The file also records rejected evidence and the reasons for rejection. A secured euro facility repayable on demand may provide little support for an unsecured, fixed-term dollar loan. Readily available information is not necessarily suitable evidence.
The tax team retains dated support. Treasury confirms the flows and financing alternatives actually accessible. Authorised decision-makers approve the terms. Blockchain records supplement the evidence of delivery; they do not establish repayment capacity or an arm's-length price.
Conclusion
For a French business, the financing file should establish the obligation, allocate the risks and identify the evidence supporting remuneration. BECTRA can prepare the transaction map, financial case and supporting file for review by the company's tax advisers and auditors. Applicable legal conclusions and tax limitations remain separately identified.
Further reading
Sources
Sources reviewed on 22 October 2026. The case and calculations are BECTRA analysis; all amounts are hypothetical.
[S1] OECD, Transfer Pricing Guidance on Financial Transactions, 2020 — Read the source
[S2] French tax administration, BOI-BIC-BASE-80-10-10, 10 December 2025, paragraphs234–235 — Read the source
[S3] French tax administration, BOI-IS-BASE-35-20, 15 July 2026, paragraphs10 and60–80 — Read the source
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