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French Finance Bill for 2024 reinforces tax authorities' power to audit and reassess transfer pricing deficiencies

23 January 2024

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Tax Alerts, Information Reporting, Legis...

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France

The French Finance Bill for 2024 provides for broadening the scope of transfer pricing documentation, making it enforceable against companies, strengthening sanctions, and facilitating the control of sales of hard-to-value intangibles. The Finance Bill for 2024 was approved by the French Parliament and published on 30 December 2023. It contains some measures affecting statutory transfer pricing (TP) requirements in France, as follows:Broadened scope for TP documentation requirements (I)Required TP documentation to become binding within the framework of tax audits (II)Increased penalties for failure to provide complete transfer pricing documentation (III)Extended statute of limitations for the transfer of hard-to-value intangible assets (IV)Expanded...