France: 2011 saw an increase in transfer pricing cases before the Conseil d’Etat

On 4 January 2011, the French tax authorities published guidelines on new requirements that had been introduced relating to specific transfer pricing documentation. The new requirements, effective as of 1 January 2010, were codified under section L 13 AA of the French tax procedure code (FTPC) and apply to certain companies in respect of transactions carried out during the subsequent fiscal year. Companies should by now have prepared the necessary documentation. Since May 2011, the French tax authorities may request disclosure of such documents in the course of a tax audit of the fiscal year. In practice, however, companies are likely to receive the first of such requests in the forthcoming months.

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