International Tax Review is part of the Delinian Group, Delinian Limited, 8 Bouverie Street, London, EC4Y 8AX, Registered in England & Wales, Company number 00954730
Copyright © Delinian Limited and its affiliated companies 2023

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.


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 & bottom lb ros

More from across our site

ITR’s latest quarterly PDF is going live today, leading on the EU’s BEFIT initiative and wider tax reforms in the bloc.
COVID-19 and an overworked HMRC may have created the ‘perfect storm’ for reduced prosecutions, according to tax professionals.
Participants in the consultation on the UN secretary-general’s report into international tax cooperation are divided – some believe UN-led structures are the way forward, while others want to improve existing ones. Ralph Cunningham reports.
The German government unveils plans to implement pillar two, while EY is reportedly still divided over ‘Project Everest’.
With the M&A market booming, ITR has partnered with correspondents from firms around the globe to provide a guide to the deal structures being employed and tax authorities' responses.
Xing Hu, partner at Hui Ye Law Firm in Shanghai, looks at the implications of the US Uyghur Forced Labor Protection Act for TP comparability analysis of China.
Karl Berlin talks to Josh White about meeting the Fair Tax standard, the changing burden of country-by-country reporting, and how windfall taxes may hit renewable energy.
Sandy Markwick, head of the Tax Director Network (TDN) at Winmark, looks at the challenges of global mobility for tax management.
Taxpayers should look beyond the headline criteria of the simplification regime to ensure that their arrangements meet the arm’s-length standard, say Alejandro Ces and Mark Seddon of the EY New Zealand transfer pricing team.
In a recent webinar hosted by law firms Greenberg Traurig and Clayton Utz, officials at the IRS and ATO outlined their visions for 2023.