Lapeyre, Wolters Kluwer, Xerox, … The last two years have been marked by a new type of dispute, characterized by the incursion of the civil judge in the determination of
Does the Wolters Kluwer case spell the end of litigation over the impact of transfer pricing on French employees profit sharing?
Creation of a procedure of hearing for anyone who can provide information on breaches relative to tax fraud and international tax evasion
Through communication right, the French tax authorities (FTA) had already the right to obtain documents held by thirds parties in order to establish tax base and to control the tax.
Two major changes in filing obligations are to be noted: The threshold above which a taxpayer should file the transfer pricing return(formulaire 2257 SD, Article 223 quinquies B du CGI)