France: modification of transfer pricing legislation – official report published

June 17, 2013

On 5 June 2013, the Minister of Economy and Finance published an official report on transfer pricing legislation.

The report is available on the website of the French Ministry of Economy and Finance.

The report concluded that France’s current transfer pricing regime is outdated and too soft on corporate taxpayers.

Consequently, the report recommends several measures to fight transfer pricing abuses.

The report recommends to:

  • Shift the burden of proof on to the taxpayer in situations involving business restructuring, transactions concerning tax havens, and structural loss position
  • Include the arm’s length principle in the wording of article 57 of the French Tax Code
  • Give the tax authorities access to cost accounting information

Further details will be reported subsequently.

Note. The announced modifications will be subject to parliamentary discussion before the end of the year.


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