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International transfer pricing developments: France

French transfer pricing environment has recently experienced significant changes. In the context of increasing focus on transfer pricing and implementation of transfer pricing rules in the legislation of many France's trading partners French tax authorities (hereafter ‘FTA’) have introduced an obligation for multinational companies to contemporaneously document their transfer prices applicable as from 1 January 2010.

Pursuant to such regulation French companies with a turnover or gross assets exceeding €400 million must keep at the tax authorities’ disposal a documentation supporting their related parties’ transactions. Such obligation also applies when the €400 million threshold is realised by direct or indirect ascendants or descendants of French companies.

The content of documentation relies on the model of documentation proposed by the European Union Joint Transfer Pricing Forum and comprises general information on the group (items covered by the ‘Masterfile’) and specific information on the associated company undergoing a tax...

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