prix de transfert flux mondiaux

The impact of a restructuring on transfer pricing policies

In a deteriorated economic environment following the Covid-19 crisis, corporate restructurings are likely to soar. A restructuring generally has great impacts on transfer pricing policies. Before specifying how to assess and limit the risks associated with transfer pricing during a restructuring, let’s start by recalling some definitions and issues. The expansion of international trade The […]

covid-19 virus

Covid-19 crisis : what consequences on transfer pricing ?

The Covid-19 pandemic has caused major changes in the economic activity of companies, and therefore in their transfer pricing policies. To date, questions remain numerous. The issue here is more about allocating losses within multinational corporate entities. The government aid, which has varied in amount between countries, makes this issue more complex. Covid-19 will push […]


GAFA Tax : towards a transfer pricing revolution ?

On Thursday, July 11, 2019, the GAFA tax (Google, Apple, Facebook, Amazon) was finally adopted by French Parliament. Indeed, the law plans to tax 3% of the sales of the digital giants. The companies concerned are those whose global sales on their digital activities exceed 750 million euros, including 25 million euros related to users […]

Transfer pricing

BEPS : strengthened requirements for justification of transfer pricing policy

The new obligations stemming from the BEPS (Base Erosion Profit Shifting) project will cause the most significant changes since the 1980s in the field of international taxation. Indeed, the countries directly involved in this project represent more than 84% of the world economy. Given the issues arising from the recovery of taxes, no doubt that […]