Transfer pricing optimization
What is transfer pricing optimization?
The optimisation of transfer prices consists of structuring and documenting financial flows between companies of the same group in order to secure international tax policy while respecting French and international tax regulations.
Transfer prices include services, royalties, intra-group financing, purchases or sales of goods between related companies located in different countries.
An effective transfer pricing strategy enables:
- Reducing the risk of tax recovery;
- Optimize the group's overall tax burden;
- Secure international operations;
- Meeting the requirements of the tax administration and the OECD;
- Effectively prepare tax controls.
Why have transfer pricing become a major issue?
Tax administrations are strongly strengthening their transfer pricing controls. In France, companies carrying out intra-group international transactions must be able to justify that their transactions comply with the arm's length principle.
A bad transfer pricing policy can result in:
- Significant tax adjustments;
- Financial penalties;
- International double taxation;
- A criminal risk in case of tax evasion.
The optimisation of transfer prices therefore involves not only reducing taxes, but also securing the group's international activity legally and fiscally.
The main strategies for optimising transfer prices
Functional and economic analysis
The first step is to analyse precisely the functions performed, the assets used and the risks assumed by each company in the group.
This analysis enables a coherent remuneration policy to be determined in accordance with international standards.
Structure of intra-group flows
Intra-group flows should be organized strategically:
- Invoicing of management services;
- Intellectual property fees;
- Intra-group financing;
- Purchasing plants;
- Distribution of international margins.
A suitable structure allows to optimize the group's taxation while maintaining full regulatory compliance.
Transfer pricing documentation
Documentation is an essential element of tax security. It demonstrates that the prices charged are in conformity with the market.
Robust documentation considerably reduces the risk of tax adjustment during control.
Tax lawyer specializing in tax optimization and transfer pricing
Our firm supports French and international groups in the implementation of secure and efficient transfer pricing strategies.
Our expertise includes:
- International tax optimization;
- Structure of intra-group flows;
- Transfer pricing documentation;
- Assistance in tax checks;
- Advance Transfer Pricing Agreements (PAPs);
- OECD and BEPS issues.
Through a legal, fiscal and economic approach, we help our clients secure their international operations while optimizing their taxation.
Why use a transfer pricing tax lawyer?
Transfer pricing has become a highly technical subject requiring perfect mastery:
- International tax law;
- Tax treaties;
- OECD recommendations;
- Tax administration practices.
Using a specialized tax lawyer helps anticipate risks, effectively defend group interests and implement tax-secured solutions.
Need support in optimising transfer prices?
Our firm works with groups of companies, international SMEs, French subsidiaries of foreign groups and executives wishing to secure their international tax strategy.
We support you in the audit, structuring and full security of your transfer pricing policy.
