International tax lawyer specializing in transfer pricing
Expertise in transfer pricing and international taxation
Transfer pricing is a major issue for international groups. Any transaction between related companies must respect the principle of arm's length in order to limit the risks of tax recovery and double taxation.
The firm supports French and international groups in defining, securing and defending their transfer pricing policy. Its intervention covers all international tax issues, taking into account OECD recommendations, tax treaties and the requirements of tax administrations.
Structure and secure intra-group flows
A transfer pricing policy must reflect the economic reality of the functions performed, the assets used and the risks assumed by each entity in the group.
The firm intervenes in particular on:
- Intragroup flow analysis;
- functional analysis;
- remuneration for strategic functions;
- fees, services and intra-group financing;
- international restructuring;
- intangible assets and DEMPE functions.
Each mission aims to secure international operations while ensuring compliance with international standards.
Preventing international tax controls
Transfer pricing is one of the main control axes of tax administrations. Insufficient documentation or inadequately justified economic policy can lead to significant adjustments, sometimes in several States.
The firm assists companies in preparing their documentation, auditing their practices and managing international tax controls. It also assists its clients in rectification procedures, litigation and amicable procedures designed to avoid double taxation.
Strategic support for international groups
The firm works with groups of companies, holding companies, technology companies, investors and executives developing international activities. Its approach combines legal expertise, understanding of operational issues and control of international taxation.
Whether it is to structure an international organisation, secure a transfer pricing policy or defend a group in the context of tax control, the firm offers tailor-made support based on expertise dedicated exclusively to international tax law.
