The development of a group's international activities more often than not impacts the business model (integration of pre-existing activities or the creation of start-ups), which has de facto consequences for transfer pricing.
The same can be said from intra-group operational reorganisations (business restructuring and supply chain), which can be the focus of particular attention from different tax authorities including the French tax authorities. In such a case, your company will have to manage both the transition itself and the determination of the post-restructuring transfer pricing policy, and more particularIy the need to:
- Analyse the restructuring operations,
- Qualify any transfers (business, assets, contracts, etc.) from a legal and tax point of view,
- Value possible transfers from an economic and tax point of view,
- Model the financial impact,
- Identify Permanent Establishments,
- Secure transfers by preparing the appropriate documentation.
