A practical hub for international businesses
Transfer pricing in France,
made clear.
Rigorous explanations of French rules, OECD standards and the decisions that matter in practice—written for international tax, finance and legal teams.
French law
Article 57, reporting duties and domestic procedure.
International framework
Article 9, OECD guidance and tax treaties.
Practical judgement
Clear distinctions between rules, methods and evidence.
Start here
Transfer Pricing Essentials
Three foundational guides explain the legal architecture, the compliance framework and the international standard applied in France.
French Legal Framework
Article 57, tax treaties and the French rules
Understand the domestic basis for reassessment, the dependency test, the alleged advantage, the burden of proof and the interaction with tax treaties.
Documentation & Reporting
Master File, Local File, Form 2257 and CbCR
Identify which French obligations apply, how their thresholds differ and why the documentation, declarations and financial records must remain consistent.
International Framework
The arm’s length principle and the French approach
Distinguish Article 9, Article 57 and the OECD Guidelines, then follow the analysis from accurate delineation to comparability, method and corresponding relief.
What do you need to solve?
Use the hub by subject, or start from the business decision currently in front of you.
Build or refresh a policy
Define the transaction, functional profile, risk allocation, pricing method and supporting evidence.
Prepare documentation and reporting
Map the applicable obligations, deadlines and data before the files are assembled.
Respond to an audit or dispute
Identify the precise allegation, preserve evidence and coordinate procedure with the economic analysis.
Prevent or relieve double taxation
Consider treaty protection, corresponding adjustments, mutual agreement procedures and advance certainty.
From rules to decisions
A disciplined analytical sequence
Transfer pricing is most reliable when legal analysis, operational facts and economic evidence are examined in the right order.
- Identify the legal basis and the applicable treaty.
- Delineate the actual transaction, functions and controlled risks.
- Select the most appropriate method and reliable evidence.
- Align contracts, conduct, accounts and documentation before an audit exposes inconsistencies.
Expert perspective
Analysis grounded in more than twenty years of transfer pricing practice
Terence Wilhelm is a French tax lawyer engaged in transfer pricing for more than twenty years. His work covers the full cycle—from policy design and documentation to audits, litigation and the management of double taxation. His teaching and doctrinal publications inform the editorial approach of this hub.
A specific issue deserves a specific analysis.
Request a focused discussion about a French transfer pricing question, project or dispute.
General information only. This website does not constitute legal or tax advice. Each matter requires analysis of its facts, applicable law, treaty and procedure.