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
Employment protection plan and transfer pricing policy, careful to the mix of genres
If the introduction of an employment protection plan can be a complicated procedure in employment law given the legal framework that this procedure benefits from, it should moreover be noted
CbCR: situation of French subsidiaries of foreign entity residing in a state that does not apply the automatic exchange of information
Under OECD recommendations, jurisdictions should require, in a timely manner, the filing of Country-by-Country declarations by the ultimate parent companies of MNE group resident in their countries and exchange this
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 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
Going further than the comparability adjustments typically made in economic analyses
The practical application of several transfer pricing methods involves comparing the profit of an enterprise (or one of its activities) with the profit of independent enterprises considered as “comparable”. The
Interests of bonds convertible into shares and VAT prorata
The Supreme Court recalls the solution held by the CJEU in the EDM case (April 29, 2004; aff.C-77/01) according to which the annual grant by a holding company of remunerated
European Commission Targets Member States’ Tax Rulings as Prohibited State Aid: Where Will it Lead?
This article was published on January 25, 2018 by the Bureau of National Affairs, Inc., Bloomberg Tax. We obtained consent of the Bureau of National Affairs, Inc., Bloomberg Tax to
Customs value – Transfer pricing adjustments
The EUCJ rejects the agreed customs value between the parties, which consisted partly of an amount initially invoiced and declared and partly of a flat-rate adjustment made after the end