In their article “Developments of the Advance Pricing Agreement Procedure in France,” Senior Managing Director Emmanuel Llinares and Consultant Sabrine Heller examine recent developments in the French advance pricing agreement (APA) program following the French tax authorities’ (FTAs’) 2025 official guidance revision and the introduction of an APA charter for interactions between taxpayers and tax authorities.
Dr. Llinares and Ms. Heller provide an overview of the APA process in France, showing growing use of the program with a reduction in average processing times. They provide a practical, step‑by‑step description of the APA procedure as implemented by the French competent authorities, from preliminary contacts and filing process to the examination, agreement, and potential renewal phases. Emphasis is placed on the main innovations introduced by the revised framework, including the formalisation of a rollback mechanism, the code of conduct introduced through the APA charter, and the reaffirmed ring‑fencing of APA information from audit teams, subject to narrow exceptions.
For MNEs that have material activities in France and significant transfer pricing exposures, the updated APA guidance offers a genuine opportunity to secure long-term certainty and reduce the risk of cross-border disputes. The revised APA framework in France offers a more structured and potentially more attractive route to certainty in an increasingly contentious international tax environment.
