About the hub
France Transfer Pricing
An expert-led knowledge hub for businesses and advisers navigating French transfer pricing rules, documentation, audits and international procedures.
Purpose
From legal rules to defensible decisions
Transfer pricing questions rarely sit in a single source. French domestic law, tax treaties, OECD standards, administrative guidance, case law and reporting obligations must be read together—and then connected to how a business actually operates.
France Transfer Pricing is designed to make that framework accessible without flattening its complexity. It identifies the applicable rule, distinguishes binding law from guidance and practice, and explains the operational consequences for international groups.
The objective is not to replace advice tailored to a particular case. It is to provide a reliable starting point, a disciplined method of analysis and a clearer basis for discussion and decision-making.
Editorial principles
Methodical, factual and practical
Authority first
Analysis begins with the relevant legal text and current official sources, with dates and scope made clear.
Distinctions matter
Domestic law, treaties, OECD guidance, administrative doctrine and practice are identified for what they are.
Practice without shortcuts
Complex rules are made usable through structure, examples and experience—without turning nuance into false certainty.
Who it serves
Built for the people who have to act
- International groups with operations or transactions involving France
- Tax, finance and legal teams responsible for policy, compliance or controversy
- Business leaders who need a clear view of risk and next steps
- Advisers, academics and students looking for a structured French perspective
Knowledge architecture
Three ways into the subject
Transfer Pricing Essentials
Core rules: Article 57 CGI, the arm’s length principle, tax treaties and French documentation and reporting.
Practical Guides
Step-by-step explanations for methods, transactions, audits and disputes.
Expert Briefings
Focused analysis of developments, decisions and points of practice.
Editorial direction
Led by transfer pricing experience
The hub is developed under the editorial direction of Terence Wilhelm, a French tax lawyer with more than 23 years dedicated to transfer pricing and international tax.
It draws on advisory, documentation, audit and dispute experience, together with teaching and sustained contribution to legal and tax publications.
Meet the author
Discover the professional experience and working principles behind the hub.
A stable resource in an evolving practice
The hub is organised around the subject, the sources and the expertise—not around a particular corporate identity. Its editorial structure is designed to remain useful as professional structures evolve.
France Transfer Pricing provides general information only. Content does not constitute legal, tax or financial advice and should not be relied upon without considering the facts and applicable law of a particular situation.