Transfer Pricing End-of-Year Adjustments in France

Though there are no specific provisions on year-end adjustments in French law and regulations, the application of the general transfer rules and a rather well-established practice are reasons to allow, and even recommend, to perform such adjustments where TNMM methods are applied. This article indicates how to properly perform and document such adjustments.

Authors

Publication Details

Journal
International Transfer Pricing Journal
Published
2024-10-28
DOI
https://doi.org/10.59403/twgqdt
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
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article

Transfer Pricing End-of-Year Adjustments in France

Bruno Gibert
International Transfer Pricing Journal
Corporate Taxation and Avoidance
article

Transfer Pricing End-of-Year Adjustments in France

Bruno Gibert
article en

Abstract

Though there are no specific provisions on year-end adjustments in French law and regulations, the application of the general transfer rules and a rather well-established practice are reasons to allow, and even recommend, to perform such adjustments where TNMM methods are applied. This article indicates how to properly perform and document such adjustments.

International Transfer Pricing JournalVol. 31(6a)
Peace, Justice and strong institutions
Openalex Percentile: Top 68%
Corporate Taxation and Avoidance
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Transfer Pricing End-of-Year Adjustments in France — Bruno Gibert · International Transfer Pricing Journal (2024) | TGRS Research Map | TGRS