Dealing Effectively with the Challenges of Transfer Pricing

image of Dealing Effectively with the Challenges of Transfer Pricing

This report addresses the practical administration of transfer pricing programmes by tax administrations. Technical analysis of how transfer prices should be computed in accordance with the arm’s length principle is outside the scope of this report. Instead the report focuses on the practical experiences of a number of FTA member countries and some non-member countries. The report discusses ways in which the management of transfer pricing programmes can be optimised, so that transfer pricing audits and enquiries are conducted efficiently and in a timely manner, for the benefit of MNEs and tax administrations alike. It is concerned with the practical steps tax administrations need to take to correctly identify transfer pricing cases that merit audit or enquiry and then to progress those cases to as early a conclusion as possible. 



Annex C: France

International issues and transfer pricing in particular are a major audit target for the French tax administration (la Direction general des Finances publiques).

la Direction general des Finances publiques recognises that, due to the complexity of transfer pricing issues, transfer pricing audits require highly technical skills and special measures (training, documentation, private databases access).

For reasons of efficiency and legal certainty, in 2008, the Central Office decided that transfer pricing audits would be performed by national and inter-regional tax audit directorates. The large companies tax audit directorate (Direction des Vérifications Nationales et Internationales - DVNI) deals with the majority of transfer pricing cases as it is in charge of the audit of main groups and big companies.


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