Transfer Pricing 2026

FRANCE Law and Practice Contributed by: Alexis Popov, Martin Serre and Stéphane Duchesne, &Co Advisory

&Co Advisory is an independent advisory firm spe - cialising in transfer pricing and valuation. The firm was co-founded in 2022 by Alexis Popov and Martin Serre, both formerly with EY France, where they re - spectively held the positions of associate partner and manager within the transfer pricing team. &Co Advi - sory provides a full range of transfer pricing services, including risk assessments, transfer pricing policy design and implementation, operational modelling, documentation (Master File and Local File), and all

types of benchmarking analyses. The firm also advis - es on valuation matters closely connected to transfer pricing, including the valuation of goodwill, shares and intellectual property, particularly in the context of business restructurings, exit tax matters and other strategic transactions. While the firm’s core market is France, &Co Advisory has also developed recognised expertise across Francophone African countries and the Maghreb.

Authors

Alexis Popov heads &Co Advisory’s transfer pricing practice. Before co-founding &Co Advisory, Alexis was an associate partner at EY France and had built more than 15 years of experience in transfer pricing advisory

Stéphane Duchesne is a senior manager in &Co Advisory’s transfer pricing practice. Prior to joining &Co Advisory, Stéphane was a manager in the transfer pricing practice at KPMG Avocats and had more than five years

within the Big Four. He was also the Head of the African TP desk at EY France for more than seven years. He is a graduate of SKEMA Business School (Lille), where he majored in Audit and Accounting, and also holds a MSTCF from Lille II University, as well as a Master’s degree in Corporate Tax. Alexis has developed particular expertise in industrial transfer pricing models, intangible assets and Advance Pricing Agreements (APAs).

of experience advising on transfer pricing matters within the Big Four. Stéphane holds a Master 2 in Business Law and Tax from the University of Orléans, covering a multidisciplinary curriculum in tax law, corporate law and business restructuring.

Martin Serre is an executive director in &Co Advisory’s transfer pricing practice. Before co-founding &Co Advisory, Martin was a manager at EY France and had built more than seven years of experience in transfer pricing

advisory within the Big Four. He holds a dual degree in Law and Management from Paris I Panthéon- Sorbonne University. He also earned a Master 1 in Tax Law from Paris I Panthéon-Sorbonne University and a Master 2 in Business Tax Law from Rennes I University. In 2025, Martin was nominated for the “Transfer Pricing Rising Star” Award by ITR.

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