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
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
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
Profit split: uncertainty remains
As part of the BEPS project, the OECD is updating its applicable transfer pricing guidelines. One of the most controversial issues in this update is the use of profit split.
Adjustments finally calculated on the endpoints of arm’s length range
In many transfer pricing audits, the tax authorities question the panel of comparables used by taxpayers to justify the arm’s length character of their transfer pricing policy. An adjustment is
Case law WB Ambassador: storm warning on intra-group loans?
In its decision of July 7, 2017 (TA Paris, 7 July 2017, n°1607683, WB Ambassador), the TA of Paris retains a strict assessment of the provisions of article 212-I of
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
The documentary obligation in France (globally) complies with BEPS recommendations
OECD recommendations on transfer pricing documentation were made public in the Action 13 report in November 2015. These recommendations are intended to clarify the information and level of detail to
What future for rulings following the European Commission’s offensive?
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
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