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(Re)Structuring of transfer pricing policy
This task provides the finance department with a clear and structured transfer pricing framework, facilitating trade-offs and decision-making in a context of changing intra-group flows.
It aims to transform practices that are sometimes historical or evolving into a policy that is clear, consistent, and usable over time, while helping to limit the risk of challenges during a tax audit.
Rethinking your transfer pricing policy for secure its intragroup flows
Structuring your transfer pricing policy is an essential step in securing intra-group flows and anticipating tax risks associated with changes in the group's organization.
The structuring of transfer pricing policy consists of defining, on the basis of functional analysis, the method applicable to a given flow, the relevant profitability indicators, and the expected level of remuneration.
It may be implemented prior to the establishment of a new intra-group transaction, or retrospectively, following a change in the group's organization, a tax audit, or an assessment that has highlighted the need to overhaul the applicable policy.
Whether it involves an acquisition, a change in business model, or internal reorganization, rethinking your transfer pricing policy ensures lasting consistency between the group's operational reality and the applicable tax framework.
Our role is to assist you in define or adapt your transfer pricing policy, in line with your operational functioning, your strategy, French legislation, and the OECD Transfer Pricing Guidelines.
Our approach
01
Analysis of the organization and intra-group flows
The structuring of transfer pricing policy is based on an in-depth functional analysis, based on actual intra-group flows and the group's actual organization.
It is based on targeted interviews with the teams concernedto understand the functions performed, the assets mobilized, and the risks assumed by each entity. It is supplemented by a review of existing documents (intra-group contracts, transfer pricing documentation, financial and accounting information), enabling operational practices to be compared with the legal and tax framework in place.
The transfer pricing policy can thus be defined based on the group's operational reality, in order to base the choices made on effective and defensible practices defensible.
02
Policy definition or adjustment
Based on the functional analysis and the information gathered, we recommend the transfer pricing policy to be implemented or adapted for the flows concerned.
This involves choosing the most appropriate transfer pricing method, theprofitability indicator to be used, and determining the economic parameters of the remuneration applicable to the entities concerned.
These choices take into account operational constraints and the quality of available data in order to select a method that is applicable and usable in practice and over time.
03
Technical assistance and implementation
Depending on your needs, we can assist with draft or review intra-group contracts, and conducting economic analyses such as margin or interest rate benchmarks, and drafting Local File modulesmodules, in line with existing documentation.
We can also provide accounting and tax reconciliation to ensure traceability and the soundness of the chosen approach.
Our level of involvement adapts to the maturity of your group in transfer pricing and the internal resources available.
(Re)think your transfer pricing policy
Secure your data flows, strengthen the consistency of your practices, and anticipate the expectations of the administration.
Marion Aguilar | Lawyer at the Marseille Bar Association
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54 Paradise Street
13006, Marseille
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