About TeaPea
Tax audits and transfer pricing disputes
Our support covers the entire process, from initial discussions with the tax authorities to the litigation phase, if necessary.
The goal is to enable you to maintain control by building consistent, technically robust positions that are tailored to each stage of the procedure.
Anticipate, manage, and defend your transfer pricing during a tax audit
Transfer pricing is now one of the main areas of focus for tax authorities, both in France and internationally.
The increase in adjustments observed in recent years reflects both the growing complexity of intra-group flows and the strengthening of the administration's analysis methods, based on an increasingly detailed economic understanding of organizations and transactions.
Beyond mere documentary breaches, challenging a transfer pricing policy can have significant direct financial impacts : an increase in the tax base, additional corporate income tax, late payment interest, penalties, and, depending on the cash flows involved, withholding taxes under applicable tax treaties.
An improvised or insufficiently structured response in the early stages of the audit permanently weakens the group's position and complicates subsequent defense, both technically and strategically.
TeaPea intervenes as soon as the tax audit begins or at any stage of the procedure in order to secure exchanges with the authorities, structure the defense strategy, and control the financial exposure associated with transfer pricing.
The presentations draw on French legislation, the OECD transfer pricing guidelines, administrative doctrine, recent case law, and practical tax audit experience in order to anticipate the reasoning of the tax authorities and sensitive points of discussion.
Our approach
01
Initial analysis and defense strategy
As soon as we receive the initial request from the administration, we analyze the situation and define the strategy to be adopted.
This step includesreviewing exposure areasin documentation and intra-group transactions,identifying legal and economicarguments that can be used, and conducting an initial assessment of adjustment risks.
This analysis enables the establishment of a clear and documented strategy, aligned with group policy and the administration's position.
02
Management of exchanges with the administration
We structure the written responses and prepare oral exchanges with the administration: defining key messages, the stance to adopt, and the supporting evidence to be produced.
When a transaction or flow has not been sufficiently documented, we can formalize the justification retrospectively, using a rigorous and consistent approach.
03
Appeals and tax dialogue
If the tax audit evolves into a challenge to the group's positions, we will activate, as necessary, the appeal procedures provided for in the tax procedure : dialogue with the audit department, referral to a higher authority or, where applicable, National Direct Tax Commission.
Each step is prepared with a strategic analysis of the arguments to be presented, in order to optimize the chances of limiting the adjustment or, if necessary, contesting its validity.
04
Litigation phase and lessons learned after review
When dialogue with the administration fails to prevent a reassessment and the case warrants it, we will defend you before the administrative courts.
Asa lawyer, TeaPea is able to support companies throughout the litigation process, providing legal and economic arguments that are consistent with the positions defended during the audit phase.
Following the audit, the lessons learned can also be incorporated to adjust the transfer pricing policy, with a view to ensuring security.
Defending your transfer pricing
Structure your defense strategy, prepare your responses, and maintain control over your transfer pricing controls.
Marion Aguilar | Lawyer at the Marseille Bar Association
Address
54 Paradise Street
13006, Marseille
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