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In a decision of 13 May 2026 (Stellantis Portugal, C-603/24), the CJEU ruled again on the connection between transfer pricing adjustments and VAT

The entry into force of the 2025 General Accounting Plan (PCG), resulting from ANC Regulation 2022-06, marks a significant development for businesses.

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 French requirements

Finance Act 2024 Transfer pricing

Public country by country declaration reporting

What is the annual transfer pricing declaration 2257-SD?

What are the French transfer pricing requirements?

To ensure that transfer pricing documentation complies with this requirement of reconciliation with your company’s accounting records, read on.

Ensure that your transfer pricing policy complies with the arm’s length principle.