FRANCE Trends and Developments Contributed by: Alexis Popov, Martin Serre and Stéphane Duchesne, &Co Advisory
Conclusion Transfer pricing in France has become both more technical and more demanding. The FTA has developed a strong capacity to analyse transfer pricing positions in depth and, at the same time, has demonstrated a greater willingness to engage with well‑supported, technically sound argu - ments. For MNEs, this creates a more challenging but also more predictable environment. Audit outcomes increasingly depend on the quality of analyses and the internal consistency of the overall transfer pricing framework. In this context, transfer pricing should be viewed as a core element of tax governance rather than a mere compliance exercise. This involves ensuring alignment between operations, documentation and financial out - comes, and relying on experienced professionals with a deep understanding of the group’s business who can build robust, tailored analyses and effectively engage in technical discussions with the tax authorities. Ultimately, the differentiating factor is no longer the mere existence of a transfer pricing policy, but its abil - ity to withstand detailed scrutiny and to be effectively defended in practice during a tax audit.
reflects the borrower’s specific circumstances and the transaction’s features. APAs and MAPs: towards a more technical and transparent dialogue The increased technical expertise of the French administration is also reflected in the use of dispute prevention (APAs) and dispute resolution mechanisms (MAPs), administered by the competent authorities within the bureau SJCF‑4B. APAs have become more structured, with clearer expectations articulated by the administration, par - ticularly through the SJCF‑4B charter issued in 2026. The process now involves more detailed exchanges and a higher level of technical engagement between taxpayers and the FTA. In practice, APA discussions are increasingly based on transparent explanations of the selected transfer pric - ing methodologies, grounded in the economic context faced by the group. This enhanced technical dialogue has also contrib - uted to greater transparency in the process. Expec - tations are more clearly defined and interactions with the competent authorities are more structured. Recent recruitments from the private sector into the SJCF‑4B team further illustrate this trend. MAP procedures reflect a similar evolution. Exchang - es between competent authorities are increasingly technical and rely on more detailed analyses, rein - forcing the importance of high‑quality documentation and robust economic reasoning. Overall, these mechanisms are likely to continue developing, as they provide a structured framework for managing complex transfer pricing issues in an environment where both taxpayers and the adminis - tration operate at a higher level of technical sophis - tication.
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