On 7 July 2020, France’s lower tax court in Montreuil held that product research costs to be invoiced by a French company to its foreign parent could be determined after
R&D tax credit deduction does not imply transfer of benefit between group companies
The US tax reform: some thoughts on transfer pricing aspects
The United States have demonstrated a great fiscal stability in recent years. However, when the United States decide to reform their tax system, it is a revolution: the reduction of
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
Lapeyre, Wolters Kluwer, Xerox, … The last two years have been marked by a new type of dispute, characterized by the incursion of the civil judge in the determination of
The Transfer Pricing documentation obligation in France now (almost totally) complies with BEPS recommendations
In order to comply with OECD standards established in Action 13 of the BEPS project, the article 107 of the Finance law for 2018 updates the content of the transfer
Taxation of the digital economy: new developments, but not yet over
This summer, France hits the headlines with Bruno Lemaire’s proposal to tax the giants of the Web, via a specific tax on turnover. In addition to the complex technical questions
CbC Reporting: Situation of French Subsidiaries of American Groups
The French tax administration has officially indicated this morning that subsidiaries and PEs in France of foreign MNEs, including US groups, do not have to file a CbCR in France
Small-sized, medium-sized companies: Transfer pricing form’s threshold lowered
Middle-market companies and SMEs have until November 3, to fill in the transfer pricing form following the lowering of the applicable threshold to €50 million. The applicable threshold for the
GE Money Bank: the question of the proof of the implicit support
In transfer pricing, the question of the burden of the proof is one of the major issues at stake. The French Supreme Court (Conseil d’Etat) decision dated June 19th, 2017
CbCR : French Tax Authorities releases the tax form
On 2 February 2017, the French tax authorities released the form 2258-SD that must be used for purposes of filing the country-by-country (CbC) report by groups falling within the scope
Country by Country Reporting: Notification obligation before December 31, 2016
In the context of the implementation of the Country by Country reporting, the OCDE offered the option for countries to introduce provisions requiring a notification from the local constituent entities