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France transfer pricing documentation guide

January 31, 2008

Cyril Maucour and Marc Bénard, of Baker & McKenzie in Paris, outline the regime for transfer pricing documentation. Additional reporting by by DLA Piper

Under French law, there is no obligation to maintain a contemporaneous transfer pricing documentation. The French tax authorities have indicated in their guidelines dated July 23 1998 (BOI 13 L-7-98) that any method used by the company to meet the arm’s length standard can be considered as valid provided it is grounded on supporting documentation concerning:




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