Transfer Pricing Documentation Requirements Likely To Come into Force as from 1 January 2010

Large enterprises established in France are likely to be required to document the transfer pricing policy applied to their transactions realized as from 1 January 2010. The tax authorities submitted for comments a third draft of legislation in April 2009 which could be included in a package with new regulations regarding tax havens. This article describes the main features of the draft legislation and addresses certain issues that it already raises.