Thomas Pautrat

The 2024 French Finance Bill (law n°2023-1322) was adopted on December 29, 2023, and has introduced new measures reinforcing transfer pricing documentation requirements as well as the power of control

Transfer pricing models implemented by Multinational Enterprises (MNE) often rely on the Transactional Net Margin Method (TNMM) to remunerate routine functions. A proper application of the TNMM involves the transfer

At the time of Paradise Papers’ revelations about numerous tax schemes involving large international groups, it is interesting to look back at the activism of the European Commission, which has