The administration benefits from the rebuttable presumption of indirect transfer of profits abroad if it demonstrates the existence of a “relationship of dependency” between a French entity and a foreign
Office Dépôt decision: the principle of non-deductibility of shareholder costs at the level of the subsidiaries of a group
The SFS France decision confirms the devolution of the burden of proof in transfer pricing
In order to benefit from the presumption of transfer of profits attached to article 57 of the French Tax Code (“FTC”), authorities must produce a double proof: Evidence of a