On 21 December 2017, the French parliament adopted the second amended finance bill for 2017 and the finance bill for 2018. These finance laws—the first of President Macron—are intended to
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.
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
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
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
The Future of Transfer Pricing – Focus on France
This article was first published in Les Cahiers de l’IFA, volume 102, The future of transfer pricing, July 2017 Download the original version of this article This article