Intra-group transfer pricing has become a major tax challenge in our increasingly global business world leading to: 

• Strong growth in cross-border trade flows
• Tighter regulations (since 1996 in France and since 2003 in Germany and Great Britain). In France, the stricter measure could result in the application of a specific penalty in the event documentation does not exist.
• A step-up in tax investigations (creation of the 30th brigade of the Direction des Vérifications Nationales et Internationales)
• Higher tax adjustments (the amount has been multiplied by three since 2002). In addition, adjustments usually lead to double taxation in the absence of mutual agreement procedures or advance pricing agreements

Our Practice Areas

• Advice to companies: planning and optimisation, advice on strategic reorganisations, economic analyses, transfer pricing audits, assistance in drafting the required documentation (in association with our Contracts department), tax implications of the chosen transfer pricing policy (on VAT, etc.)
• Assistance during tax audits
• Negotiations with the Tax Administration and more particularly in connection with applications for advance pricing agreements.
   

Our Approach

• Multi-disciplinary teams combining our entire tax and legal expertise in a field that requires the involvement of a number of different specialists.
• Comprehensive analysis of economic issues through a dedicated team of economists with recognized capabilities in transfer pricing, business valuation and management of international projects in this field, who work closely with the lawyers handling the matter.
• International experience through a network of specialists with relevant expertise in the European, American and Asian markets.
• Supporting the client in its transfer pricing approach and assisting in the decision making process. 
• Practical experience due to the diversity of cases handled by the firm’s lawyers and economists (French groups abroad and French subsidiaries of foreign groups). 
• Recognised expertise in interacting with the tax administration, both during investigations and in negotiating advance pricing agreements.

Our clients

Major French groups with international operations and foreign groups with operations in France, in sectors as diverse as textiles, automobile, luxury goods, pharmaceuticals, medical equipment, high technology, clothing, packaging, mail order sales, hygiene and household cleaning products, and consultancy.

Our team

For each transfert princing matter, we put together a specific team composed of economists and specialists in national taxation, international taxation,  tax on turnover, customs and excise regulations and, when necessary, contracts and intellectual property law. The team is headed by a partner, who is the client’s principal contact point. These teams also work on transnational cases carried out by CMS.