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General Information |
Transfer Pricing
Transfer pricing can have serious tax consequences in our increasingly global business world. Globalisation has led to:
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Strong growth in cross-border trade flows
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Tighter legislation (since 1996 in France and since 2003 in Germany and Great Britain)
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Numerous and complex tax investigations, conducted by specialized teams
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Higher tax adjustments (the amount has been multiplied by 4 since 1995)
In addition, adjustments usually lead to double taxation in the absence of mutual agreement procedures or advance pricing agreements
Our Practice Areas
- Tax advice : planning and
optimisation, strategic reorganizations, economic analyses, transfer
pricing audits, assistance in drafting the required documentation (in
association with our Contracts group), tax implications of the chosen
transfer pricing policy (on VAT, business tax, etc.)
- Assistance during tax audits
- Negotiations with the authorities and more particularly in applications for advance pricing agreements
Our Approach
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Multi-disciplinary teams combining tour entire tax and legal expertise in a field that requires the involvement of a number of different specialists.
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Comprehensive analysis of economic issues through a dedicated team of economists with recognized capabilities in transfer pricing, business valuation and managing international projects in these fields, who work closely with the lawyers handling the client's engagement.
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International experience through a network of specialists with relevant expertise in the European, American and Asian markets.
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Support and decision-making assistance in the client's transfer pricing approach
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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).
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Recognised expertise in dealing with the tax authorities, both during investigations and in negociating advance pricing agreements (five APAs granted, including a multilateral one, and four pending application).
Our clients
Major French groups with international operations and foreign groups with operations in France, in sectors as diverse as textile, automobile, luxury goods, medical equipment, high technology, pharmaceuticals, clothing, packaging, mail order sales, hygiene and house cleaning products, and consultancy.
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| CONTACT
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Transfer pricing is a complex issue that requires a team comprising national and international specialists tailored to each specific assignment.
Your usual tax contact will take care of putting together a team which best suits your needs.
We have established dedicated teams for:
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| COMMENTS TRANSACTIONAL PROFIT METHODS
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On February 27, 2006, the OECD issued to the community of practitionners, taxpayers and tax administrations an invitation to comment, regarding a set of issues in connection with the use of transactional profit methods, as described in the current OECD Guidelines on transfer pricing. These methods have become more and more important over time in business reality, both for defining and for justifying the transfer pricing policies implemented by a large number of multinational companies of all industries and origins. Therefore, CMS Bureau Francis Lefebvre, as well as other member firms of the CMS Alliance, decided to provide a detailed contribution on this topic. This contribution was jointly produced, under the overall coordination of Bruno Gibert and Arnaud Le Boulanger, by the member firms of the CMS Alliance in 9 countries, including France, and leverages on the deep, practical experience that transfer pricing experts of the CMS Alliance have developed over a number of years. It was presented to the OECD on August 31, 2006.
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| CONTRIBUTION OF CMS ALLIANCE
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