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.

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  1. Review of applied / envisaged transfer pricing policies
  2. Analysis of their adherence to the arm's length principle
  3. Identification of the risks associated with the transfer pricing policy applied / envisaged changes
  4. Recommendations for securing cross-border transactions
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  1. Setting-up new transactions or TP policies for the creation of foreign subsidiaries / international expansion
  2. Proposal of several TP model options, adapted to group operations
  3. Redesign / adaptation of TP policies during restructurings (e.g., mergers / acquisitions)
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We also offer support services to help implement the planned changes in a practical way:

  1. Review and drafting of agreements
  2. Assistance in calculating intra-group flows
  3. Performance monitoring
  4. Training and support for in-house teams
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Economic analyses (‘benchmarks’) are used to determine / justify the remuneration of the activities of French or foreign entities:

  1. Services (e.g., management services, sales support, etc.)
  2. Distribution, Manufacturing, etc.
  3. Remuneration for intangible assets (technology / brand / know-how)
  4. Valuations (securities, assets)
  5. Financial transactions (cash pool, loans)
  6. 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.

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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

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Our experience in tax audits allows * :

  1. Development of defense strategies
  2. Assistance with the various stages of a tax audit (data collection & analysis, economic analyses, impact calculations, etc.)
  3. 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.

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Our mission / purpose : Make the day-to-day practice of transfer pricing simpler for business leaders.

+30 years

Cumulative experience in BIG 4