This article was produced by Olswang LLP, which joined with CMS on 1 May 2017.
Julien Monsenego, head of our French tax practice, and Charlotte Robert, Paris tax associate, reply to three questions related to Transfer Pricing documentation in France.
Issue 1: use by the French tax authority of the full list of information that is required by the template in transfer pricing risk assessments.
Issue 2: willingness of the French tax authority to use the Profil Split Method.
Issue 3: preparation of the French tax authority to adopt a global formulary apportionment of profit.
This article was published in BNA, The Bureau of National Affairs, in September 2014. To read the full article, click here.