International corporate tax and transfer pricing
Transfer pricing, setting up abroad, withholding taxes and tax audits. Securing the tax position of groups that grow beyond borders.
Supporting companies that cross borders
Growing internationally means taking on complex tax challenges.
We advise companies on structuring and securing their cross-border operations, taking into account tax treaties, local regulations and developments in international tax law.
Whether it involves investments abroad, international operations, intragroup flows or preventing the risk of double taxation, we build tailored solutions that combine effectiveness, legal certainty and compliance with international standards.
You are growing your business internationally
Investment abroad, setting up a subsidiary, a new location, financing the group’s entities, reorganization.
- Investments and operations abroad: structuring upfront
- Intragroup financing: capitalization, debt, agreements
- Permanent establishment risk in France or abroad
- Transfer of functions, assets or activities between entities
Your intragroup flows must be secured
Transactions between related companies, royalties, cost re-invoicing, intragroup services and financing.
- Transfer pricing policy and the arm’s length principle
- Documentation: Master File, Local File, functional analyses
- Benchmarking studies and arm’s length ranges
- Withholding taxes and application of tax treaties
- Preventing and eliminating double taxation
You are facing a tax audit
An audit of your transfer pricing or your withholding taxes, through to litigation if necessary.
- Review of the regularity of the procedure and the deadlines
- Responses to the tax authorities and technical arguments
- Administrative appeals and defense of your position
- Securing your policies for the future
A different situation? A first conversation lets us map out what is at stake.
Reading the group as a single system
International taxation is not handled flow by flow.
Transfer pricing, permanent establishment, withholding taxes and intragroup financing are not separate topics. A decision made in one country has consequences in another. Looking at them in isolation leaves blind spots that come at a cost during an audit.
We take up the group’s value chain and its intragroup flows, then read them against the OECD principles and the applicable tax treaties. Every position is documented, with functional and economic analyses, benchmarks, Master and Local File, so that it is defensible before the tax authorities, not merely presentable.
An international matter involves several jurisdictions. We coordinate the analyses with local tax advisors in the countries concerned, so that the positions taken stay consistent across the group, from one country to another and over time.
Your questions on international corporate tax
The questions that come up most often among groups expanding internationally.
01 When should you consult on your company’s international taxation? +
There are four decisive moments. Before setting up abroad or creating a subsidiary, to structure upfront. When defining or reviewing your intragroup flows, to set a defensible transfer pricing policy. As soon as you receive an audit notice, to secure the procedure. And during a reorganization, which often shifts functions and risks without the tax consequences being measured. The earlier we step in, the wider your room for decision.
02 What is transfer pricing, in practice? +
These are the prices charged between companies in the same group for their transactions: sales of goods, services, financing, royalties on intangible assets. The tax authorities check that they respect the arm’s length principle, that is, the terms independent companies would have agreed. A poorly designed or poorly documented policy exposes the group to sometimes substantial reassessments.
03 Does my company need to prepare transfer pricing documentation? +
Depending on the size of the group and the applicable thresholds, structured documentation, a Master File and Local File, may be mandatory. Even without any obligation, it remains the best protection in the event of an audit, because it justifies your prices with functional analyses and benchmarks. We assess your actual obligation, then build or update this documentation.
04 How does an audit of transfer pricing unfold? +
The tax authorities examine your intragroup flows and whether your policy is consistent with the reality of your activities. We first check the regularity of the procedure and compliance with the deadlines, then prepare the responses and technical arguments, and defend your position through to administrative appeal or litigation if necessary.
A first conversation to map out your international tax challenges.
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