The French Council of State has upheld some months ago a very interesting position regarding to the possible gaps which may arise as to the valuation of trademarks and more generally of IP assets. It was held that there is no irregular management action when a trademark is assigned for only 1 (one) Franc by a mother company to its sub-company and when, a few days later, this very same trademark is valued at 10 (ten) million Franc (!) in the context of an assignment to a competitor of the titles constituting that sub company. Who said that valuation of IP assets was not a subjective approach? This decision is at least a main point to consider towards the fiscal administration.