FRANCE TRENDS AND DEVELOPMENTS Contributed by: Caroline Silberztein, Benoît Granel, Jean-Baptiste Tristram and Laura Nguyên-Lapierre, Baker McKenzie
Another illustration of the notable recent devel - opments is the French competent authorities’ work to develop an APA charter for taxpayers. This charter, published on April 16th 2025, is accessible on the official website of the French tax administration and aims to improve trans - parency, efficiency and collaboration between taxpayers and the competent authorities in the context of APA. The APA process requires co- operation between the enterprise and the com - petent authorities, making it essential to estab - lish and maintain a relationship of trust founded on transparency, co-operation and loyalty from all parties involved. The APA charter is designed to strengthen the commitments between the taxpayer and the competent authorities in order to optimise the APA process. It synthesises the APA admin - istrative guidelines and add some reciprocal commitments in terms of collaboration and deadlines. The APA charter addresses various aspects such as confidentiality, the procedures of instruction and the commitments between the parties, as well as information on the outcome of the APA request and the monitoring of the APA throughout its duration. It includes a list of the documents required at different stages of the process.
Given the commitments included in the APA charter, it is optional for taxpayers in 2025. Conclusion While in recent years the tax authorities’ focus has been on the strict enforcement of trans - fer pricing regulations and the fight against tax avoidance, it is encouraging to note a shift towards two pillars, increasing tax certainty. The latest developments in dispute prevention and resolution in France highlight significant strides in enhancing legal security and improv - ing the efficiency of dispute prevention and resolution procedures. The strengthening of tax authorities’ resources and the initiatives outlined above collectively contribute to a more robust and efficient legal framework, benefiting both taxpayers and the authorities involved. That being said, there is still progress to be made, particularly in reducing the processing times for both MAP and APA procedures, which remain key to achieving effective tax certainty.
164 CHAMBERS.COM
Powered by FlippingBook