Although the Article does not cover specific financing schemes to be put in place, the following elements shall be taken into account: when entering the tax consolidation regime, groups of undertakings must consider how best to minimise the application of joint and several liability in respect of the group`s income tax liabilities. They must also consider how the subsidiaries finance the payment of these debts by the main company. Both of these issues can be managed by groups of companies through tax-sharing agreements and tax financing agreements. Alternatively, if your customer has these agreements, has the customer brought in or out of the group? It is important that all member companies are parties to the agreements. Please call a member of our team if you need help. Ultimately, it is up to the courts to decide whether there is a reasonable allocation…