Respective scope of the substance over form theory and transfer pricing in a French audit

Article Abstract:

The coverage of substance over form is limited by the French book of tax procedures, however recent decisions by the French Supreme Administrative Court has set out a general principle on the application of the theory. Transfer pricing regulations and how it is applied to avoid the transfer of profits among multinational enterprises are discussed.

Tax Law, Public Finance Activities, France, Tax evasion, Report

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Arm's length principle, exit tax and commensurate with income standard: some practical thoughts on the new German transfer pricing rule 2008

Article Abstract:

The new German transfer pricing policies encompassed in the International Transactions Tax Act are discussed. The statutory priority of the comparable uncontrolled price, resale minus, and cost plus methods in determining transfer prices are explained thoroughly to clear any ambiguities associated with the tax law.

Germany, Taxation, Foreign corporations, Pricing policies, Law overview

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