French ruling clarifies burden of proof
June 08, 2011
Sophie Ashley - TPW
A French company has lost its appeal at the Nantes Administrative Court over the burden of proof and the assignment of affiliated company liabilities in transfer pricing.
Grimaud Frѐres Sélection, a French food manufacturer, was reassessed by the French Tax Administration (FTA) over the salary paid to the general manager of its Chinese affiliate. The FTA added back this salary to the French company’s taxable income.
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