About TeaPea
Transfer pricing documentation
In practice, transfer pricing documentation is the tax authorities' preferred starting point in analyzing transfer pricing issues. It therefore largely determines how discussions are conducted during an audit.
Beyond compliance with legal obligations, the challenge for the finance department is to have documentation aligned with operational practices, based on robust economic analyses and usable over time.
TeaPea's intervention is part of this approach: producing structured, coherent, and sustainable documentation that is structured, coherent, and sustainable, without unnecessary complexity or theoretical frameworks that are difficult to justify or maintain over time.
Prepare compliant and defensible transfer pricing documentation
Preparing compliant and complete transfer pricing documentation (Master File and Local File) is mandatory in France for groups whose annual revenue (excluding VAT) or gross assets on the balance sheet exceed €150 million, in accordance with Article L.13 AA of the Book of Tax Procedures.
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 assists companies with the implementation, review, and updating of their transfer pricing documentation (Master File, Local File, Form 2257-SD), taking into account their organizational structure and intra-group transactions with a clear objective: to produce compliant, consistent, and defensible.
Our approach
01
Initial review and scoping
Our support begins with a targeted analysis of your situation : applicable obligations, group structure, nature and volume of intra-group flows, level of existing documentation, and availability of accounting, legal, and economic data.
This framework allows priorities to be identified and the robustness of elements already in place to be assessed.
02
Structuring of documentation
We prepare transfer pricing documentation in accordance with the requirements of Article L13 AA of the Tax Procedures Code and the OECD Transfer Pricing Guidelines.
The Master File and the Local File are prepared or updated to cover all the expected modules: group structure, description of activities, intangible assets, financial policy, functional analysis, and methods used.
03
International coordination and compliance
When specific local documentation is required, we work in coordination with your usual advisors or a partner firm from our international network.
This approach ensures documentary harmonization and full tax compliance across the entire scope of the group.
04
Annual update and declaration
When reusing existing documentation, we ensure a smooth transition : maintaining the previous logic when it remains relevant, or clearly documenting any adjustments made.
We also structure the documentation so that it can be easily updatable internally, in the absence of major changes.
Finally, we take care of the 2257-SD declaration, from analyzing the trial balance to verifying consistency with the documentation and submitting the form ready for submission.
Are you required to file TP documentation or Form 2257-SD? Please answer 6 questions to find out.
TeaPea
TP Diagnosis
Your transfer pricing documentation requirements in France
Question 1 of 6
This analysis is provided for informational purposes only. It does not constitute legal advice and is not a substitute for an analysis conducted by a qualified professional. Sources: Art. L.13 AA of the French Financial Act (LPF), Art. 223 quinquies B of the French General Tax Code (CGI), BOI-BIC-BASE-80-10-40.
Prepare your transfer pricing documentation
Ensure compliance with your transfer pricing obligations, strengthen the consistency of your positions, and anticipate the expectations of the tax authorities in the event of an audit.
Marion Aguilar | Lawyer at the Marseille Bar Association
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54 Paradise Street
13006, Marseille
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