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France: Recent trends in transfer pricing, survey

Transfer pricing trends in France

The European Commission recently published new rulings, the OECD published its base erosion and profit shifting (BEPS) final reports, and many countries are reviewing and reinforcing their transfer pricing rules—and France is no exception.


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Tax professionals in France have observed certain recent trends with regards to transfer pricing. The current French environment reveals a willingness by the French tax authorities to seek more taxes from multinational corporations, and there is a general feeling that individual taxpayers are paying more and more in taxes to the government—while large corporations are not “paying their fair share” of taxes. 

Other transfer pricing-related trends reflect:

  • The tax rules now require even more transfer pricing documentation and declaration requirements.
  • The tax authorities are moving to impose “bad faith” penalties in more cases when there is a transfer pricing assessment.
  • It is becoming more difficult to attain relief from double taxation through a mutual agreement procedure (MAP) process, as in many other countries.
  • Advance pricing agreements (APAs) are becoming more difficult to handle—especially given the EU environment and the lack of resources within the French tax administration.

Transfer pricing survey

Against this background, and given the increasing attendant pressure on multinational groups, FIDAL* (an independent law firm that KPMG member firms work with on a regular basis in France) is conducting a survey to better understand what current perceptions, practices, expectations, and constraints businesses have in the area of transfer pricing.   

If you have business interests in France and would like to take part in the survey, you can access FIDAL’s survey here.  FIDAL has confirmed that all answers to the questionnaire will be processed anonymously.


For more information, contact a tax professional with the Global Transfer Pricing Services group (FIDAL*) in Paris:

Anne-Laure Goetzinger | + 33 1 47 38 89 32 |

Olivier Kiet | + 33 1 55 68 1615 |

Pascal Luquet, | + 33 1 55 68 15 22 |

Kate Noakes | + 33 1 55 68 16 57 |

Nadia Sabin | + 33 1 55 68 17 38 |


* FIDAL is an independent legal entity that is separate from KPMG International and its member firms.

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