In two recent cases, the judges had to rule on the relevance of the method used by the French tax authorities to challenge the price of intra-group transactions, which they considered to be below market value. The tax administration merely asserted that the historical market risk method should be used, without demonstrating that the projected market risk method approach used by the taxpayer was inappropriate. The Court also appeared to consider that a deviation of 11% is presumed not to be significant, so that such a difference cannot be regarded as a transfer of profit.