Transfer pricing law firm
TeaPea, a law firm exclusively dedicated to transfer pricing
TeaPea is a French law firm exclusively dedicated to transfer pricing, founded by Marion Aguilar, a member of the Marseille Bar. The firm draws on more than eight years of experience in transfer pricing, gained both at a Big Four firm—where she worked with the most rigorous technical and methodological standards—and in the tax department of an international group, at the heart of the company’s operational, financial, and organizational challenges.
The firm assists international groups with the structuring, documentation (Master File, Local File, Form 2257-SD), and defense of their transfer pricing policies, in accordance with the OECD Principles and French legislation (Article 57 of the General Tax Code, Article L. 13 AA of the Tax Procedure Code).
Its work is distinguished by a rigorous technical approach and a resolutely pragmatic implementation.
Her History
A lawyer at the Marseille Bar, Marion Aguilar has been practicing transfer pricing law for over eight years.
She began her career in 2017 in the transfer pricing department of EY Société d'Avocats in Lyon, where she assisted numerous international groups in structuring their intra-group flows, preparing transfer pricing documentation, and in the context of tax audits and mutual agreement procedures.
In addition to her work as a lawyer, she provides initial and continuing training in transfer pricing at Jean Moulin Lyon III University.
In 2021, Marion joined the group's headquarters CMA CGM, one of the world leaders in maritime transport and logistics, in the Transfer Pricing department, as a dedicated expert.
She is involved in steering the group's transfer pricing policy on a global scale, with a particular focus on intra-group financial flows, including loans, cash pools and guarantees, intra-group restructuring, support functions (management fees, IT fees), as well as transactions specific to the maritime transport sector.
She is also involved in transfer pricing aspects of tax audits, as well as coordinating mutual agreement procedures.
In 2026, she founded TeaPea, a law firm exclusively dedicated to transfer pricing, in order to offer companies expert, responsive, and tailored support, providing an alternative to standardized approaches.
Her Experience
2026 - Present
Founder – TeaPea, a law firm specializing in transfer pricing
2021–2025
CMA CGM – Transfer Pricing Department | Transfer pricing expert with a cross-functional role in managing and documenting transfer pricing policy across the group.
2017–2021
EY Société d’Avocats – Lyon | Transfer pricing lawyer | Assisting international groups with transfer pricing issues, including structuring intra-group flows, transfer pricing documentation, and tax audits.
Our approach in transfer pricing
Proximity and expertise in transfer pricing
Support provided by a single, experienced contact person who is directly involved at every stage.
This approach guarantees consistency, continuity, and technical quality in the handling of your transfer pricing cases, with personalized follow-up and no intermediaries.
Responsiveness
Responsiveness and clarity in managing your transfer pricing
Our agile approach enables quick responses without unnecessary delays.
You receive clear and actionable deliverables that are compatible with your tax deadlines and internal requirements (budgets, closings, intra-group projects).
Constant responsiveness, so that technology works for your schedule—not the other way around.
Concrete solutions for your transfer pricing challenges
- Practical recommendations that can be applied immediately.
- Expertise gained in law firms working with numerous international groups, and in the tax department of an international group.
- Mastery of complex intragroup flows, transfer pricing documentation, and enhanced tax audits.
A relationship based on trust
TeaPea prioritizes a working relationship based on proximity, transparency, and availability, with an experienced lawyer directly involved at every stage of the collaboration.
The terms of service andfees are defined in advance, and communication is direct, without intermediaries, in a clear and constructive dialogue.
This approach enables long-term collaboration based on reliability and constant monitoring of cases.
Why hire a transfer pricing attorney
Transfer pricing refers to the financial terms applied to transactions between related entities within the same international group. In France, Article 57 of the General Tax Code allows the tax authorities to adjust a company’s financial results when the prices charged to a related foreign entity differ from those that would have been agreed upon between independent companies.
Given the complexity of this subject—which combines tax law, economic analysis, and operational considerations—consulting a lawyer specializing in transfer pricing helps ensure that the company’s intra-group policies are legally sound, prepare documentation that complies with the requirements of Article L. 13 AA of the Tax Procedures Code, and effectively defend the company’s positions in the event of a tax audit.
Unlike the standardized approaches offered by large audit firms, a law firm specializing in transfer pricing provides tailored support, greater responsiveness, and the benefit of attorney-client privilege, which protects all communications between the client and their counsel.
FAQ: Transfer Pricing Attorney
When should you consult a transfer pricing attorney?
It is recommended to consult a specialized attorney as soon as a transfer pricing policy is implemented or modified, when preparing annual documentation, or in advance of a tax audit or an intra-group restructuring. Engaging an attorney early on allows for the anticipation of risks and helps safeguard the group’s positions.
What is the role of a transfer pricing attorney compared to that of an audit firm?
A transfer pricing attorney provides legal expertise that audit firms cannot offer under the same conditions. Attorney-client privilege protects all communications with the client, which is particularly valuable when preparing for a tax audit or litigation. The attorney can also represent the company before administrative courts and participate in settlement negotiations.
What are the risks of not having transfer pricing documentation?
Failure to provide documentation or the submission of incomplete documentation exposes the company to a specific fine provided for under Article 1735 ter of the General Tax Code (a minimum of 10,000 euros, which may be increased to the higher of 10,000 euros or 5% of the transferred profits). Beyond the fine, the lack of documentation significantly weakens the company’s position in the event of a tax audit.
Does TeaPea operate only in Marseille?
No. Although the firm is based in Marseille, TeaPea operates throughout France and assists international groups with their transfer pricing issues, regardless of their location. Communication takes place primarily remotely, with in-person visits as needed for each case.
Need a support in transfer pricing?
Talk directly with Marion Aguilar, a transfer pricing lawyer, to explain your situation and get some initial insight.
About TeaPea
Marion Aguilar | Lawyer at the Marseille Bar Association
Address
54 Paradise Street
13006, Marseille
© 2026 TeaPea
Prepare compliant and defensible transfer pricing documentation
Preparing compliant and complete transfer pricing documentation is mandatory for groups whose turnover or gross assets exceed €150 million, in accordance with the OECD Guidelines and Article L.13 AA of the Tax Procedures Book.
This obligation applies not only to entities that directly exceed this threshold, but also to those that own or are more than 50% owned, in France or abroad, by a company exceeding this threshold.
Furthermore, groups whose turnover or gross assets exceed €50 million must file the 2257-SD declaration, summarizing their main intra-group transactions, within six months of filing their tax return.
Even below these thresholds, all companies remain obligated, in the event of an audit, to be able to justify the compliance of its transfer prices with the arm's length principle, based on objective economic factors.
TeaPea supports companies in set up, review, and update their transfer pricing documentation (Master File, Local File, 2257-SD declaration), taking into account their organization, intra-group flows, and legal obligations, with a clear objective: to produce documentation that is consistent, usable, and defensible.