Relevance of Comparable Transactions and Assessment Methodology for Evaluating Intra-Group Transactions: Case Law

In two recent cases, the judges had to rule on the relevance of the method used by the French tax authorities to challenge the price of intra-group transactions, which they considered to be below market value. The tax administration merely asserted that the historical market risk method should be used, without demonstrating that the projected market risk method approach used by the taxpayer was inappropriate. The Court also appeared to consider that a deviation of 11% is presumed not to be significant, so that such a difference cannot be regarded as a transfer of profit.

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Publication Details

Journal
International Transfer Pricing Journal
Published
2025-06-30
DOI
https://doi.org/10.59403/13abapg
Primary Topic
Construction Project Management and Performance
Type
article
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article

Relevance of Comparable Transactions and Assessment Methodology for Evaluating Intra-Group Transactions: Case Law

P-J. Douvier, H. Jeambon
International Transfer Pricing Journal
Construction Project Management and Performance
article

Relevance of Comparable Transactions and Assessment Methodology for Evaluating Intra-Group Transactions: Case Law

P-J. Douvier, H. Jeambon
article en

Abstract

In two recent cases, the judges had to rule on the relevance of the method used by the French tax authorities to challenge the price of intra-group transactions, which they considered to be below market value. The tax administration merely asserted that the historical market risk method should be used, without demonstrating that the projected market risk method approach used by the taxpayer was inappropriate. The Court also appeared to consider that a deviation of 11% is presumed not to be significant, so that such a difference cannot be regarded as a transfer of profit.

International Transfer Pricing JournalVol. 32(4)
Openalex Percentile: Top 82%
Construction Project Management and Performance
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Relevance of Comparable Transactions and Assessment Methodology for Evaluating Intra-Group Transactions: Case Law — P-J. Douvier, H. Jeambon · International Transfer Pricing Journal (2025) | TGRS Research Map | TGRS