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Transfer pricing

Our expertise for your strategic operations

Transfer pricing is at the forefront of international taxation matters, as demonstrated by the BEPS project, the latest works on Pillar 1 and the increasing number of disputes (regarding interest payments or intangible properties, for example): the rules in this area are becoming progressively more complex with an increasing number of documentary and reporting requirements, and the evermore severe associated penalties, making this a key issue for managing your company's tax affairs.  

A strategic exercise with serious tax consequences

Our teams can help you elaborate strategic planning that meets the needs of your operational structure and transfer pricing policy, in drafting your documentation (with comparative studies for all types of flows) or even verifying that you are up to date with your reporting requirements. We can help you with transfer pricing inspections by the authorities, your defence at the pretrial stage or during proceedings, or with negotiation procedures, such as prior transfer pricing agreements, out-of-court settlements or arbitration. 

We can call upon a wide range of expertise when, for example, a complex restructuring transaction involving transfer pricing issues also has aspects that require the valuation of companies or assets

Blended expertise to better understand your issues

Our teams, which combine economists and tax experts with multi-sectoral experience, provide appropriate solutions to the different issues faced by their clients.  

Drawing upon their significant experience, our experts have worked with major groups and SMEs in sectors as diverse as consumer goods, luxury goods, IT, high-tech, telecommunications, energy, finance, the automotive industry, large-scale distribution, aeronautics, textiles, pharmaceuticals and consultancy, to name but a few. Through our CMS organisation, which operates in more than 50 countries, we can provide cutting-edge expertise at a local level, regardless of the sector. 
 
Our specialists are also involved in the way international taxation is evolving. They regularly contribute to the work of the OECD with tax authorities to promote pragmatism and a fair balance taking into account the interest of companies of all sizes, and publish their analyses in leading reviews. 

Transfer pricing

Events

  • France
    21 Apr 2026

    On the Pulse webinar series 2026 - Spring/Summer

  • France
    28 Apr 2026

    IP Insights webinar series 2026

  • France
    02 May 2026

    CMS at INTA 2026

  • France
    05 May 2026

    Joint seminar with CMS and Tannenbaum Helpern - A global perspective on securing, maintaining, and enforcing...

  • France
    28 May 2026

    CMS International Crypto Forum 2026

Local market knowledge. Global outlook

We provide future-facing legal advice to help your organisation thrive. Combining local market knowledge and a global perspective, and with lawyers in locations worldwide, your organisation benefits from the expertise it needs, even across borders.

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