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The French Finance Act for 2026 allows the use of a market rate for the deductibility of interests paid to minority corporate shareholders for fiscal years ending on or after December 31, 2025. To date, being an associated company was the only way to exceed the reference rate.

OECD effective mutual agreement manual procedures

The management of intangible assets is challenged by transfer pricing controls: a question of legal ownership and economic ownership

The annual transfer pricing return (form 2257-SD) must be submitted electronically within six months following the corporate income tax return filing deadline.

Transfer pricing litigation has not escaped the trend in recent years towards the penalisation of tax law.

The annual transfer pricing return (form 2257-SD) must be submitted electronically within six months following the corporate income tax return filing deadline.

Public CbCR available in June

Transfer pricing: identify your documentary and declarative obligations

Transfer Pricing French requirements

Finance Act 2024 Transfer pricing

Public country by country declaration reporting

What is the annual transfer pricing declaration 2257-SD?

Find out the specifics of the transfer pricing policy statement 2257-SD

Find out the main features of the new Directive introducing country-by-country reporting (CbCR).

The OECD two-pillar solution and the corporate taxation of the digital economy and large global firms

The specificities of the 2020 transfer pricing return 2257-SD