Transfer pricing when losses arise : France

Part of "Comparative survey : transfer pricing when losses arise". The country specialists comment on this issue from their practical experience.The articles produced on this topic are designed to explore the treatment of current economic difficulties (particularly losses arising from a variety of sources) within the transfer pricing world. Specifically, the following issues have been suggested to the authors: the selection of comparables when the data reflects strong economic years; situations in which overall (corporate-wide) losses arise in one or more products that may bring about the problem of which entity should bear those losses and whether loss-sharing is approved in each country; tax aspects of losses that may arise due to start-ups (either of an affiliate or the introduction of a new product line), inefficient management, downturns in the economy of only one (or a few) of the countries in which the MNE conducts business, because the company's products are out-of-date (R&D failure), or for other reasons.