Transfer Pricing Forum -- France
1 June 2010
By Sébastien Gonnet
In this article from BNA International's Transfer Pricing Forum, NERA Senior Consultant Sébastien Gonnet discusses the application of the Transactional Net Margin Method (TNMM) in France. Like in most countries, TNMM is widely used by French Multinational Enterprises (MNEs) to set and test the arm's length nature of their intra-group transactions. The French tax authorities also rely on this method in most tax audits. In the context of the OECD Guidelines revisions (notably in relation to the TNMM), this article discusses the key challenges faced by both MNEs and tax authorities with respect to the application of this method in France.
