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CAMBIO Avocat can help you draw up your transfer pricing documentation.
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CAMBIO Avocat can draft your transfer pricing documentation in order to comply with your obligations in France (described in article L 13 AA of the Livre des Procédures Fiscales)
CAMBIO Avocat can help you prepare this document, which will enable you to respond more effectively to the auditor's requests during a tax audit of your transfer pricing policy.
CAMBIO Avocat can review your transfer pricing documentation and suggest the necessary changes to ensure compliance with the requirements in France (described in article L 13 AA of the Livre des Procédures Fiscales).
CAMBIO Avocat can help you map out the various local obligations in terms of transfer pricing documentation and specific declarations.
Assignments involving the drafting of transfer pricing documentation are invoiced on a lump-sum basis.
This gives you a clear idea of the total cost of my support.
Frequently asked questions
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French law does not require a strict deadline for preparing documentation.
Since 2024, transfer pricing documentation has been enforceable against companies. This means that the transfer pricing policy described in the documentation must correspond to the one applied. Any deviation is considered by the French tax authorities as a transfer of profits abroad.
Preparing the documentation in the months following the end of the financial year allows you to ensure that the transfer pricing policy described is consistent with the one implemented and to make any adjustments if necessary.
In the event of a tax audit, you have 30 days from the date of the auditor's request to submit the documentation.
Companies that are obliged to have documentation may be subject to fines in the event of a tax audit if the documentation is missing (or insufficient).
These fines are a minimum of €50,000 per audited fiscal year and can reach:
In its administrative instructions, the French tax authorities recommend to have "contemporary documentation".
It is therefore strongly recommended that the documentation is updated every year, especially from 2024 onwards when the documentation becomes binding on companies.
By updating the documentation annually, you can better ensure that the transfer pricing policy described in the documentation is in line with the one that has been applied.
The French law (Loi Toubon) aims to guarantee the use of French in dealings with the administration. However, the use of French is recommended but not compulsory for companies in the private sector.
In practice, the Master File is generally drafted in English because it is a document that is common to all group entities. The Local File may be drawn up in French or English, which is a language increasingly accepted by the French tax authorities.
the auditor is not very comfortable with English, he or she may ask for a translation of all or part of the transfer pricing documentation.
For companies subject to the obligation to have transfer pricing documentation (article L 13 AA of the Livre des Procédures Fiscales), the documentation consists of two documents:
France follows the OECD documentation model (presented in Action 13 of the BEPS report).
For companies that are not subject to this obligation, there is no particular formalism concerning the document describing their transfer pricing policy.
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