Hot Topics – Transfer Pricing in France

Companies operating in France must prepare a Local File, Master File, and Country-by-Country Report in line with the OECD Guidelines and French tax law.

The French authorities place strong emphasis on the arm’s length principle, reviewing transactions involving services, royalties, financing, and goods.

Recent trends include:

• Increased use of data analytics and digital tools in tax audits
• Greater focus on economic substance and documentation quality
• A growing emphasis on transparency and proactive risk management

Dispute resolution mechanisms in France include Mutual Agreement Procedures (MAPs) under double tax treaties, which are actively used to resolve transfer pricing conflicts. Additionally, Advance Pricing Agreements (APAs) are gaining traction as proactive tools for achieving tax certainty, with both unilateral and bilateral APAs available to multinational groups. Other recent mechanisms are also offered by the French tax administration to avoid double taxation and secure international transactions with France.

Join our webinar
To help you navigate this complex environment, Deloitte Denmark is hosting a webinar with Eric Lesprit, Partner at Deloitte France and former senior official within the French tax authority.

Eric Lesprit will share:

• Practical insights into France’s transfer pricing framework
• Guidance on documentation and risk management
• Updates on recent audit trends and dispute resolution strategies

The webinar will conclude with a live Q&A session, offering you the opportunity to discuss specific transfer pricing challenges and questions related to France.