Transfer pricing

In an international tax environment marked by increased transparency and enhanced controls, transfer pricing has become a central strategic lever for international groups.

Beyond a simple regulatory requirement, they are a structuring tool for managing value creation, at the crossroads of fiscal, financial and operational issues.

Our tax law firm supports French and international groups in the design, security and defence of robust transfer pricing policies aligned with the most demanding standards.

A strategic approach to transfer pricing

Transfer pricing is not limited to a documentary obligation. They reflect how a group:

• allocates its functions and risks;
• value its assets, including intangible assets;
• organizes its financial and commercial flows.

In this context, each transfer pricing policy must meet a dual requirement:

• compliance with international standards (OECD, BEPS);
• economic coherence with the operational reality of the group.

We intervene at a strategic level, integrating governance, performance and overall tax risk management issues.

Expertise dedicated to complex environments

We accompany groups with sophisticated problems:

• international structuring and global value chains;
• valorisation of intangible assets (IP, brands, technologies);
• intra-group reorganizations;
• complex intra-group financing;
• digitisation of economic models.

Our approach is based on a fine understanding of sectoral economic models and the expectations of tax administrations.

Structure and security of transfer pricing policies

Integrated policy design

We develop custom transfer pricing policies that are integrated into the group's overall strategy:

• definition of remuneration models;
• alignment with value creation;
• secure cross-border flows.

High Value Added Documentation

Beyond formal compliance, we design defensible and strategic documentation:

• Master File and Local File;
• in-depth functional analyses;
• robust comparability studies;
• anticipation of the positions of tax administrations.

International tax risk management

We put in place risk control mechanisms:

• reviews of existing policies;
• tax exposure simulations;
• simulation of fiscal control.

Tax controls and transfer pricing disputes

Transfer pricing controls have become more technical, more aggressive and often coordinated among States.

Our firm intervenes at each stage:

• preparation and control strategy;
• managing trade with administrations;
• defending the Group's positions;
• bilateral or multilateral negotiations;
• litigation.

We favour an approach combining technical rigour and strategic intelligence of negotiation.

Advance Agreements and Long-Term Security (APA)

We accompany the groups in negotiating Advance Transfer Pricing Agreements (APAs) in order to achieve multi-year legal certainty.

This approach allows:

• anticipate the risks of double taxation;
• stabilise fiscal positions;
• enhance the Group's financial visibility.

A signature: excellence, discretion, commitment

Our firm is distinguished by:

• recognized expertise in international taxation;
• an ability to intervene on high-level issues;
• a culture of result and confidentiality;
• tailor-made support for the fiscal and financial directorates.

We work closely with the Group's legal, tax and international boards.

Transfer pricing: a governance issue

Today, transfer pricing is at the heart:

• tax transparency requirements;
• investor expectations;
• reporting obligations (CbCR, enhanced documentation).

They participate fully in the overall governance and reputation of international groups.

Contact a transfer pricing lawyer

We support groups wishing to structure or secure their transfer pricing policy in a demanding international environment.

Contact our firm for a confidential exchange with a specialized tax lawyer.