Francois Hollande's government brings transfer pricing amendments to France

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement


Francois Hollande's government brings transfer pricing amendments to France

Francois Hollande's just-elected French government has proposed new measures to increase tax revenues, including changes to the transfer pricing regime.

francois-hollande-150.jpg

As new President Francois Hollande has a majority in parliament, the likelihood of the measures being passed is high and illustrates the government’s desire to strengthen the French Tax Administration’s authority on tax avoidance.

The changes target abusive corporate income tax strategies and state that the burden is on French companies, rather than the authorities, to demonstrate that any subsidiaries in tax havens have real substance and do not merely exist to avoid tax..

Companies can no longer deduct payments to subsidiaries, particularly those overseas, from their taxable profits if the objective of the subsidy is only financial (in that it is only for tax purposes).

Taxpayers that reduce their operations in France through cuts in production, closing sites, reducing profits or reducing assets cannot carry forward tax losses.

Any company that is part of a merger or takeover will no longer be allowed to transfer losses to other companies in the group unless the same level of production and employment is maintained.



more across site & shared bottom lb ros

More from across our site

Brazil's tax system is being reshaped by VAT , pillar two and TP reform. Fallet explains why those changes convinced him to lead a new practice
The agreement with Daribatech, alongside recent high-profile investment in talent, suggests the firm is gearing up for a significant push in the region
Several factors have led to a steady transition of TP work away from traditional advisers and towards full-service law firms, DLA Piper’s new TP leader says
Julian Balson's departure from EY's Tier 1 tax controversy practice for lower-ranked Fieldfisher represents one of the more eye-catching UK hires of the year
Former IRS commissioner Danny Werfel argues that the biggest obstacle to AI adoption in tax is not technology, but trust, and introduces a practical AI risk framework to help
Howell takes a deep dive into how he led the landmark PepsiCo dispute, discusses the ATO's enforcement priorities, and emphasises KordaMentha's market ambitions
Global tax leader David Linke said that the TaxSim gaming programme could replace aspects of traditional face-to-face learning
Former ATO economist Craig Silverwood is joining from Australian firm MinterEllison
The rebranding, which will see changes to signage, visual identity and digital properties, is scheduled to be completed by the end of this year
The software space was previously more fragmented, but that model is becoming more difficult to sustain as tax administration becomes increasingly digitised
Gift this article