France’s Finance Bill for 2024, adopted on December 16, through article 22, introduces four measures reinforcing the French tax administration’s control of transfer pricing policies applied by multinational groups operating in France:
- Lowering of the thresholds for Master File/Local File requirements, now capturing a wider range of French subsidiaries of middle-sized groups.
- Higher penalties for missing or incomplete transfer pricing documentation.
- Shifting to the taxpayer the opposability and burden-of-proof rules for transfer pricing documentation and related reassessments.
- Adoption of the OECD’s Hard-to-Value Intangibles (HTVI) ex post control approach, combined with an extension of statute of limitations to six years for transfers of HTVIs.