Recently, Transfer pricing audits have become a significant part of the tax audits carried the French tax authorities. The DVNI is the specific department in charge of the control of multinational companies (as from €M 150 of turnover). DVNI has 500 employees and carries out around 1,200 tax audits per year. With a total amount of tax adjustments of around €20 Billion per year, the DVNI represents € 5.8 Billion per year among which €2 Billion corresponds to transfer pricing tax adjustments. Transfer pricing adjustments affect not only corporate income tax but also trigger withholding taxes on the deemed distributed profits and the local tax adjustments.
Key Highlights of the Webinar
With this objective in mind, we invite you to an informative webinar where we will discuss the following:
- Transfer Pricing documentation requirement in France
- Main approach used by the French tax authorities for price checking
- Tax adjustments – global settlement: process and potential outcomes
- Transfer pricing documentation requirements
- Transfer pricing vs. Thin capitalization rules: Approaches used by the DVNI and the regional Paris and Paris region (Dircofi) tax squads
- The Google case: anti-abuse provisions and criminal charges
- The perspectives of the transfer pricing tax audits in France: “Unified Approach” under Pillar 1 – OECD
