Our Integrated Transfer Pricing Solutions
We offer a complete range of solutions, from diagnosis to implementation, including structuring, benchmarking and compliance with local and international standards. Our expertise ensures optimal management of cross-border flows while minimizing tax risks.
Diagnosis
- Review of applied / envisaged transfer pricing policies
- Analysis of their adherence to the arm's length principle
- Identification of the risks associated with the transfer pricing policy applied / envisaged changes
- Recommendations for securing cross-border transactions
(Re)structuring
- Setting-up new transactions or TP policies for the creation of foreign subsidiaries / international expansion
- Proposal of several TP model options, adapted to group operations
- Redesign / adaptation of TP policies during restructurings (e.g., mergers / acquisitions)
Implement
We also offer support services to help implement the planned changes in a practical way:
- Review and drafting of agreements
- Assistance in calculating intra-group flows
- Performance monitoring
- Training and support for in-house teams
Benchmark
Economic analyses (‘benchmarks’) are used to determine / justify the remuneration of the activities of French or foreign entities:
- Services (e.g., management services, sales support, etc.)
- Distribution, Manufacturing, etc.
- Remuneration for intangible assets (technology / brand / know-how)
- Valuations (securities, assets)
- Financial transactions (cash pool, loans)
- Etc.
Depending on the customer’s needs – impact simulations, documentation, tax audits – these analyses can be used to determine or justify the remuneration received by certain Group entities, depending on the nature of the transactions/activities in which they are involved.
Conform
Local file & Master file
In France, applicable to companies with sales/gross assets of EUR 400m or which own or hold entities meeting these criteria (>50% capital or voting rights).
Lowering of the thresholds, starting with the 2024 financial year (threshold of EUR 150m).
TP “2257-SD” form
Other
Our experience in tax audits allows * :
- Development of defense strategies
- Assistance with the various stages of a tax audit (data collection & analysis, economic analyses, impact calculations, etc.)
- Assistance in drafting procedural documents (responses to rectification proposals, responses to taxpayers’ observations, etc.) *.
* This assistance will be provided in collaboration with our partner law firms.