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Transfer pricing and business and asset valuation

France

Transfer pricing and business and asset valuation are key challenges for taxation. The multi-sector experience of our team of economists and tax specialists will provide solutions that are perfectly matched to your specific needs in these areas.

Transfer pricing is at the forefront of international taxation matters, as demonstrated by the BEPS project: the rules in this area are becoming increasingly complex, documentary and reporting requirements increasingly numerous and associated penalties increasingly strict, making this a key issue for managing the tax affairs of your company. Our team can help you think about strategic planning that meets the needs of your operational structure and transfer pricing policy, by conducting audits and preparing documentation to ensure that your intra-group transactions are conducted at arm’s-length prices (carrying out benchmark studies or even financial valuations) or that you are up to date with your reporting requirements. More generally, we can help you with transfer pricing inspections by the authorities or with negotiation procedures, such as prior transfer pricing agreements, for example.

The valuation of a business or its assets is crucial to transfer and restructuring operations. These days, the valuation of intangible assets, which often make up the principal value of a company, has major tax implications. Using economic and financial analysis techniques that are in keeping with the recommendations of the tax authorities and in line with the approaches adopted by practitioners, our team can play a consultancy role for any company reorganisation, by valuing securities, intangible assets or optional instruments, or for any family-related matters. We can also act in any pre-litigation or litigation with the authorities.

Drawing upon their significant experience, our experts have worked with major groups and SMEs in sectors as diverse as automobiles, large-scale distribution, aeronautics, textiles, pharmaceuticals and consultancy, to name but a few. Through our CMS network, which has a presence in more than 40 countries, backed up by a network of “best friends” located all over the world, 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 in the field of transfer pricing and valuation, taking an active role in organisations such as the European Union’s Joint Transfer Pricing Forum, contributing regularly to the work of the OECD and publishing their thinking in leading journals such as Wolters Kluwer, Bloomberg BNA, etc.

Whatever the help you need, our experts can offer you the best solutions.

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29/02/2016
Trans­fer Pri­cing | A stra­tegic ap­proach for glob­al busi­ness per­form­ance
As shown by the re­cent works at G20, OECD, European or UN level, mul­tina­tion­al en­ter­prises (MNEs) have to ad­apt to rap­idly chan­ging leg­al and eco­nom­ic en­vir­on­ments:le­gis­la­tions and prac­tices evolve con­stantly...
05 October 2016
Vous aid­er à évalu­er vos ac­tifs et réal­iser une mod­él­isa­tion fin­an­cière...
Dé­cis­ives pour péren­niser la valeur de votre en­tre­prise ou de votre pat­rimoine, les opéra­tions de re­struc­tur­a­tion et de trans­mis­sion des ac­tifs im­pli­quent des en­jeux con­sidér­ables et soulèvent de...

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08/06/2020
Sim­pli­fied trans­fer pri­cing de­clar­a­tion
In a press re­lease dated April 17, 2020, the Min­is­ter of Pub­lic Ac­tion and Ac­counts an­nounced that the dead­line for fil­ing the cor­por­ate in­come tax pack­age for com­pan­ies with fisc­al years end­ing 31st...
27 July 2018
Trans­fer pri­cing doc­u­ment­a­tion in Al­ger­ia
A. Trans­fer pri­cing doc­u­ment­a­tion re­quire­ment 1. In your jur­is­dic­tion, are tax­pay­ers ob­liged to main­tain trans­fer pri­cing doc­u­ment­a­tion? Does this ob­lig­a­tion ap­ply to all tax­pay­ers, or only to cer­tain...
10/04/2017
Strength­en­ing the EU Ar­bit­ra­tion Pro­ced­ure
The fight against base erosion and profit shift­ing and the guar­an­tee of ef­fect­ive double tax­a­tion dis­pute res­ol­u­tion mech­an­isms are closely knit con­cerns. Pre­vent­ing tax fraud and avoid­ance is im­port­ant...
20 October 2016
The OECD want Mul­tina­tion­als to Pay their “Fair Share”: Se­lec­ted As­pects...
Pan­el 3 The OECD want Mul­tina­tion­als to Pay their “Fair Share”: Se­lec­ted As­pects of BEPS New York State Bar As­so­ci­ation In­ter­na­tion­al Sec­tionCO-CHAIR­SNY: James R. Short­er, Jr., Short­er Law Of­ficesEU:...
04/08/2016
The New Per­man­ent Es­tab­lish­ment Status After BEPS: Déjà Vu In France?
The fi­nal re­port on Ac­tion 7 of the BEPS ini­ti­at­ive (Pre­vent­ing the ar­ti­fi­cial avoid­ance of Per­man­ent Es­tab­lish­ment Status – OECD – Oc­to­ber 2015) pro­poses to amend sig­ni­fic­antly Art­icle 5 of the OECD...
18 July 2016
Grupo RLD, Miguérès Moulin and CMS Bur­eau Fran­cis Le­fe­b­vre ad­visors to...
Grupo RLD, Miguérès Moulin and CMS Bur­eau Fran­cis Le­fe­b­vre are ad­vising the French and Span­ish bed­ding lead­er, the Pikolin group, in its stra­tegic al­li­ance with Stein­hoff In­ter­na­tion­al, Europe's second...
29/02/2016
Trans­fer Pri­cing | A stra­tegic ap­proach for glob­al busi­ness per­form­ance
As shown by the re­cent works at G20, OECD, European or UN level, mul­tina­tion­al en­ter­prises (MNEs) have to ad­apt to rap­idly chan­ging leg­al and eco­nom­ic en­vir­on­ments:le­gis­la­tions and prac­tices evolve con­stantly...
29/02/2016
Trans­fer Pri­cing | A stra­tegic ap­proach for glob­al busi­ness per­form­ance
As shown by the re­cent works at G20, OECD, European or UN level, mul­tina­tion­al en­ter­prises (MNEs) have to ad­apt to rap­idly chan­ging leg­al and eco­nom­ic en­vir­on­ments:le­gis­la­tions and prac­tices evolve con­stantly...
08/06/2015
Bruno Gibert re­appoin­ted as Chair­man of the EU Joint Trans­fer Pri­cing For­um
Bruno Gibert, a part­ner at CMS Bur­eau Fran­cis Le­fe­b­vre, has been re­appoin­ted for the third time as Chair­man of the EU Joint Trans­fer Pri­cing For­um, a body es­tab­lished by the European Com­mis­sion in 2002...
06/05/2015
Trans­fer pri­cing news­let­ter - May 2015
Prac­tic­al con­sequences of not hav­ing a trans­fer pri­cing doc­u­ment­a­tion While trans­fer pri­cing doc­u­ment­a­tion re­quire­ment is not a new is­sue, it re­mains more than ever top­ic­al. Over the last years, many...
15/07/2013
CMS Tax Con­nect e-Guide: Trans­fer Pri­cing: Man­aging doc­u­ment­a­tion re­quire­ments...
The guide provides CMS’s in­ter­na­tion­al cli­ents, par­tic­u­larly those hav­ing in­tra-group activ­it­ies across Europe, Asia, the Maghreb re­gion, the US and the BRICs coun­tries, with con­sist­ent and prac­tic­al...
19/07/2012
Tax Con­nect | In­creas­ing budget re­quire­ments of European coun­tries - im­plic­a­tions...
Since Sum­mer 2011, we have wit­nessed an un­pre­ced­en­ted sov­er­eign debt crisis in Europe. A highly tense G20 sum­mit and some fif­teen European sum­mits seem to have sta­bil­ised the situ­ation in fin­an­cial terms...