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.

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?

Review the compliance framework →

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?

Explore the international standard →

Editorial roadmap

Practical Guides

Methods & Transactions

Guides devoted to the economic analysis and pricing of recurring or high-value controlled transactions.

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

  1. Start with the foundational guide for the applicable legal layer.
  2. Move to the practical guide for the transaction or procedure.
  3. 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.