The Criminalization of Transfer Pricing in France: What the Future Holds

12 October 2022
Hosted By: NERA and Bredin Prat

Multinationals increasingly face the threat of legal action related to allegations of tax evasion and improper transfer pricing arrangements in France, with hundreds of millions of euros in evaded taxes alleged. In recent years, US companies have been the subject of investigation by the French National Financial Prosecutor’s Office (Parquet National Financier (PNF)).

In a complimentary webinar on 12 October 2022 at 12:00 pm EDT (6:00 pm CET), NERA Transfer Pricing Practice Chair Dr. Emmanuel Llinares will join Yves Rutschmann, Pierre-Henri Durand, and Julien Gayral of Bredin Prat to discuss the evolving tax and transfer pricing regulatory and legal environment US companies face in France.

In particular, the panel will offer insight on: 

  • The 2018 French Anti-Fraud Act, which imposes an obligation to report certain facts to the public prosecutor onto tax authorities;
  •  The various factors that can trigger investigations for tax fraud or money laundering by the public prosecutor;
  • Recent practices of the tax authorities and specialized magistrates regarding settlements, transactions, and negotiated justice;
  • The impact of these rules and practices on transfer pricing controversies; and Possible approaches to mitigate the risks for US companies.


Dr. Emmanuel Llinares
Transfer Pricing Practice Chair
NERA Economic Consulting

Yves Rutschmann
Bredin Prat

Pierre-Henri Durand
Bredin Prat

Julien Gayral
Bredin Prat

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