Knowledge centre
Transfer Pricing Guides
A structured route through French law, compliance obligations, OECD standards and the practical decisions faced by international businesses.
Available now
Transfer Pricing Essentials
Begin with the three layers that must remain connected but distinct: the French domestic rule, the compliance framework and the international arm’s length standard.
French Legal Framework
Article 57, tax treaties and documentation
When France may adjust profits, how dependency and advantage are analysed, how the burden of proof operates and how treaties interact with domestic law.
Core question: what precisely must the French tax authority establish?
Documentation & Reporting
Master File, Local File, Form 2257 and CbCR
Separate the principal French obligations, their thresholds, deadlines and purposes, then understand how the resulting information must remain consistent.
Core question: which obligation applies to which entity and when?
International Framework
Article 9, OECD Guidelines and the French approach
Move from accurate delineation and comparability to method selection, arm’s length ranges and corresponding relief without confusing guidance with domestic law.
Core question: how is the arm’s length principle actually applied?
Editorial roadmap
Practical Guides
Methods & Transactions
Guides devoted to the economic analysis and pricing of recurring or high-value controlled transactions.
- Choosing the most appropriate transfer pricing method — coming soon
- Comparability studies and arm’s length ranges — coming soon
- Intra-group services and management fees →
- Financial transactions and guarantees →
- Intangibles, royalties and DEMPE functions — coming soon
- Business restructurings — coming soon
Two practical guides are available now. Additional guides will be published progressively.
Audits & Disputes
Guides for anticipating scrutiny, responding to an adjustment and coordinating domestic and international remedies.
- Transfer pricing audits in France
- Information requests, evidence and burden of proof
- Penalties and procedural safeguards
- Advance pricing agreements
- Mutual agreement procedures
- Corresponding adjustments and double-taxation relief
This series will combine procedural accuracy with practical audit experience.
Expert Briefings
Short analysis when the framework moves
Focused notes examine significant French case law, BOFiP updates, legislative changes and OECD developments. They explain what changed, who is affected and what should be reviewed.
Latest briefing: Gap France and the limits of reusing a comparable set →
How to use this library
- Start with the foundational guide for the applicable legal layer.
- Move to the practical guide for the transaction or procedure.
- Check the primary sources and current date before acting.
Primary sources remain essential
Each guide separates explanation from authority and links to the applicable official materials.
Need a focused view of a specific situation?
Where a question is time-sensitive, fact-specific or commercially significant, an expert consultation can help identify the relevant issues and next steps.
General information only. This library does not constitute legal or tax advice. Each matter requires analysis of its facts, applicable law, treaty and procedure.