Transfer Price Lawyer

Secure your international transfer pricing policy

Transfer pricing is a major issue for international groups conducting transactions between related companies. The provision of services, sales of goods, intra-group financing, intellectual property royalties or distribution operations must be determined on the basis of the arm's length principle enshrined in the OECD Principles and national tax laws.

In view of the strengthening of documentary obligations and the intensification of international tax controls, it is essential to establish a coherent, documented transfer pricing policy in line with the requirements of different jurisdictions.

The firm supports French and international groups in structuring, securing and defending their transfer pricing policy.

Our transfer pricing interventions

Development and Review of Transfer Pricing Policy

Each group presents its own organization and economic model. The firm analyses the functions performed, the assets used and the risks assumed by each entity in order to define a transfer pricing policy in accordance with the arm's length principle.

This approach helps to secure intra-group flows while limiting the risks of tax administrations calling into question.

Documentation of intra-group transactions

International groups may be subject to documentation requirements to justify their transfer pricing policy. Appropriate documentation is an essential element in demonstrating compliance with transactions during tax checks.

The firm assists its clients in preparing, updating and reviewing their documentation to meet French and international requirements.

Support during tax checks

Transfer pricing is one of the main topics discussed in the international group controls. Upstream preparation helps to anticipate the demands of the administration and effectively defend the policy implemented.

The firm intervenes at all stages of the procedure, from prior audit to assistance in dealing with tax administrations and, where appropriate, in litigation or amicable proceedings to avoid double taxation.

Increasing international challenges

Tax administrations are strengthening their cooperation and are now exchanging more information. In this context, transfer pricing policies are being further monitored, particularly in the context of OECD international work to combat artificial transfer of profits.

An appropriate transfer pricing policy helps to secure international transactions, prevent the risk of tax recovery and limit double taxation situations that may affect several companies within the same group.

Expertise in international taxation serving groups

Transfer pricing cannot be analysed independently of all international tax issues. They are part of a global reflection that integrates international tax treaties, stable institutions, cross-border restructuring, international financial flows and group tax governance.

The firm supports companies of all sizes, from companies in the internationalization phase to groups established in several jurisdictions, in order to build a transfer pricing strategy in line with international standards and adapted to their operational challenges.

Anticipate risks and secure your international operations

A robust transfer pricing policy is a real tool for managing international tax risks. A regular analysis of intra-group flows, valuation methods used and documentary obligations can be used to anticipate difficulties, strengthen legal certainty of transactions and safeguard the group's interests in the face of French and foreign tax administrations.