Transfer Pricing in France in 2009

Sun Jan 31 15:24:38 EST 2010
By Sébastien Gonnet with Julien Monsenego of Dechert LLP

In this article from Tax Planning International Transfer Pricing, NERA Senior Consultant Sébastien Gonnet and Julien Monsenego of Dechert LLP review the major transfer pricing developments that transpired in France in 2009. Significant developments from that year include new documentation requirements effective from January 2010 and recent Court decisions relying on the economics of the case. The authors note that these changes highlight, more explicitly than before, key features of transfer pricing challenges being faced by both governments and multinational enterprises. This article describes the new documentation requirements, reviews the most recent transfer pricing cases in France, and explains how French developments are in line with and representative of international developments.