About TeaPea
Transfer pricing risk assessment
Risk diagnosis provides a clear and prioritized overview of the group's exposure in terms of transfer pricing.
It offers an experienced external perspective, based on the practice of tax audits, enabling the identification of truly sensitive areas and the exclusion of secondary issues.
Once the diagnosis has been made, the decisions to be taken are clarified : targeted security measures, adjustments to be considered, or confirmation of the robustness of existing practices.
Anticipate your transfer pricing risks
The transfer pricing risk assessment aims to evaluate the compliance of your practices and identify areas of vulnerability that could be called into question during a tax audit.
The international groups are increasingly exposed to tax audits relating to transfer pricing. An insufficiently justified intra-group transaction or incomplete documentation can result in heavy tax adjustments, with significant financial impacts.
The diagnosis allows for a targeted assessment of your situation, in particular by: identifying risky operations, assessing the robustness of your documentation, measuring your tax exposure, and proposing concrete solutions to secure your practices.
This is a particularly relevant approach prior to a reorganization or structural operation, when transfer pricing policies have not been reviewed for several financial years, in anticipation of a tax audit or simply for the sake of compliance.
The analysis is based on the requirements of the French tax authorities (Article 57 of the General Tax Code), the OECD Transfer Pricing Guidelines, as well as recent case law and practical experience of tax audits, enabling us to anticipate the most frequently challenged points.
Our approach
01
Framing and initial analysis
The mission begins with a structured exchange aimed at understanding the organization of the group and its intra-group flows (services, sales, financing, royalties, etc.).
This framework allows for the rapid identification of risk areas and the initiation of analysis of existing documents : tax returns, contracts, and transfer pricing documentation (Master File, Local File, 2257-SD forms).
02
Functional interviews
Based on this initial analysis, we conduct targeted interviews with your financial, legal, and/or operational teams.
This step helps to understand the actual role of each entity, the functions performed, the assets used , and the risks assumed.
Discussions can be conducted remotely or on-site when the issues warrant it, in order to fully capture the group's value chain of the group.
03
Technical analysis and OECD compliance
The analysis is conducted in accordance with the OECD Guidelines, incorporating recent case law and the expectations of the French tax authorities.
This approach guarantees legal certainty and robustness of your transfer pricing policy.
04
Restitution and action plan
At the end of the assignment, we present a structured summary :
- mapping of identified risks,
- tax exposure assessment, and
- recommendations tailored to your context.
The goal is to provide a clear and actionable vision, facilitating the concrete implementation of the necessary adjustments.
Identify your transfer pricing exposure
Identify your transfer pricing risks, assess your level of exposure, and anticipate the challenges associated with a tax audit.
Marion Aguilar | Lawyer at the Marseille Bar Association
Address
54 Paradise Street
13006, Marseille
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