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
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
CbCR: OECD clarifications on its implementation
Following on from the BEPS and in particular Action 13 reports, the OECD has recently published three important documents aiming at providing greater legal certainty for tax administrations and multinational
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
Amazon: IRS loose again
In the March 23rd, 2017 decision Amazon.com, Inc. v. Commissioner, T.C., No. 31197-12, 148 T.C. No. 8, the US Tax Court concluded that the United States tax authorities had an
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