Deloitte Société d'Avocats

News on transfer pricing obligations in France: towards documentation for all

Two major changes in filing obligations are to be noted:

If we take into consideration the ongoing discussions of the European Union on lowering the country-by-country reporting threshold and making it public, we are witnessing the emergence of true “transfer pricing democratization” that may impact all companies that operate internationally. This also raises the difficult issue of the preparation of SMEs to potential questions from tax authorities. Even without a strict documentation obligation, tax authorities may question groups’ transfer pricing policy, with potentially serious financial consequences. You can observe it in practice with tax audits that are ever more transfer pricing focused, even on small structures.