Relating to the purchase of an existing SARL and creance / comptes courants
I am buying existing company (SARL X) in Paris and reviewing the paperwork. I have seen that the Cedant of the Cession de Compte Courant (SA Y) is the majority shareholder and a non-French corporation, but SA Y did not invest / loan any funds to SARL X. In fact, the owner/Cedant of the Creances is an entirely different French societé - EURL Z - which loaned funds directly to SARL X.
Furthermore, neither SA Y or EURL Z is the gerant / dirigeant of SARL X. My understanding of the pertinent French regulation is that a Compte Courant must be an investment / loan into SARL X made by either a shareholder or a dirigeant in order for it to be treated as a compte courant for tax purposes.
Therefore, IMO neither SA Y nor EURL Z has a true compte courant to sell from SARL X. EURL Z has a DEBT, but that will not be treated as a tax-free Compte Courant to the buyer (ME) upon withdrawal in the future. Am I missing something? Or is the above description correct? If it is inaccurate or incorrect, please explain where I got it wrong.