About TeaPea
International transfer pricing security
The use of international transfer pricing procedures can be a structuring lever to prevent or resolve situations of double taxation and provide visibility on the group's international tax treatment.
For the tax department, the challenge is to choosing the right approach, anticipate its implications, and manage its implementation in a controlled manner, taking into account financial issues, deadlines, and operational constraints.
TeaPea's intervention aims to support the finance department in a strategic and pragmatic approach to these procedures, in order to derive real benefits and avoid inappropriate or insufficiently targeted approaches.
Anticipate and manage the risks of double taxation in terms of transfer pricing
Double taxation situations in transfer pricing most often result fromdiffering analyses of intra-group flows by different tax administrations.
A transfer pricing adjustment, even if limited to a single jurisdiction, can lead to double taxation when it relates to income that has already been taxed in another country, in the absence of an automatic corrective mechanism.
To avoid or correct this type of situation, several mechanisms can be used: the international amicable procedure (MAP), advance pricing agreements (APAs), the European dispute resolution mechanism provided for in Directive (EU) 2017/1852, the relationship of trust, and the tax ruling on transfer pricing.
When used in a targeted manner, these tools can provide visibility on the tax treatment of certain intra-group flows and limit or correct situations of double taxation, within a structured framework for dialogue with the relevant authorities.
Our approach
01
Choosing the right device
We begin with an analysis of the group's context and objectives, focusing in particular on the feasibility of the proposed system, the deadlines, and financial implications and its consistency with the overall strategy.
This step helps identify the most appropriate mechanism—whether it be an amicable procedure (MAP)or a advance pricing agreement (APA) or another mechanism – and to define its strategic outlines, or, if necessary, conclude that such recourse is not appropriate at this stage.
02
Technical and legal preparation
We compile a technically structured file that complies with the legislation of the country or countries concerned, and the OECD Guidelines and, where applicable, the applicable framework, in particular Directive (EU) 2017/1852.
The analysis focuses on the transactions concerned, the methods used to determine them, and the economic justifications that can be used in the proceedings.
The goal is to construct a rigorous argument, technically sound and legally consistent, likely to win the support of the tax authorities involved.
03
Conducting and monitoring the procedure
We handle relations with the French tax authorities and coordinate with the relevant foreign tax authorities as part of exchanges between administrations.
Our support includes drafting correspondence, preparing meetings, and presenting economic and legal arguments throughout the proceedings.
Each step aims to maintain a consistent and controlled position, taking into account the evolution of discussions and the issues identified.
04
Implementation and post-procedure support
Once the procedure has been completed, we assist the group in the operational implementation of the agreement reached and in updating the corresponding transfer pricing documentation documentation.
Where relevant, we also assist with the formalization of the internal procedures necessary for implementing the agreement and aligning future practices with the positions adopted.
Secure your transfer pricing
Anticipate the risks of double taxation, stabilize your positions, and initiate a controlled dialogue with tax authorities.
Marion Aguilar | Lawyer at the Marseille Bar Association
Address
54 Paradise Street
13006, Marseille
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