Arsene Taxand - Transfer Pricing

Head by Antoine Glaize, the Taxand Transfer Pricing department was awarded Best Transfer Pricing Team in France in 2009 by International Tax Review.
Team of 5, exclusively dedicated to our expertise, we work with corporations – in particular for clients who either have their head office or a decision centre in France - on the various economic and strategic aspects of a transfer pricing policy and the production of the related documentation, both centrally and locally with the support of our Taxand network offices, including notably recommendations on operational implementations relative to the transfer pricing policy, all of which very often conditions its success and efficiency:

We help our clients define their transfer pricing policy and implement their documentation

• Transfer pricing policy design: appropriate and efficient diagnosis of transfer pricing policy as well as recommendation for its improvement and implementation of proposed changes.
• Documentation : documentation of what already exists; justification of a transfer pricing policy, implementation of new French documentation obligations, challenging of the price setting policy, adaptation to the pricing setting policy, analysis of target situations taking into account the economic environment.

We support the operational strategy through the Supply Chain and the strategic management of intangible assets in accordance with the international and national regulations in force

• Functional analysis of the Group.
• Economic analysis of considered transactions and definition
• Financial analysis of global tax based on the allocation of functions and risks,
• Assessment and securing of tax risks,
• Valuation of intangible assets (trademarks and patents) for tax purposes.

We defend the transfer pricing policy of our clients in the context of litigations or pre-litigations with Tax Authorities

• Tax audit assistance: Definition and implementation of defense strategy, management of the relationship with Tax Authorities, negotiation with Tax Authorities…
• Negotiation of advanced pricing agreements and mutual agreement/arbitrage procedures: initiation of procedures, assistance during the negotiation phase with competent authorities, management of the consequences relative to the agreement.

• Awarded Best French Transfer Pricing Team for the year 2009 by the reference International magazine, Tax Review.
• -Exclusive specialization of the team concerning Transfer Pricing issues
• Approach suited to the needs of our clients and also at the service of business, in accordance with operational requirements
• High economic competence: transfer pricing (analysis of the different issues, research of comparable elements, analysis of margin distribution, etc), valuation of intangible assets (in particular marketing or manufacturing), financial relations (intra-group loan and capitalization, transfer pricing relations in banks) and, more generally, economic analyses with regard to tax (assets valuation, research and development tax credit, etc.)
• Ability to combine tax and financial valuation skills,
• The capacity to intervene on transversal and international issues with the Taxand network. Antoine Glaize heads the Transfer Pricing Service Line within the Taxand network.
• Antoine Glaize used to be in charge of transfer Pricing control policy when he was in position with the government some years ago ; Antoine was also responsible for the implementation of the French APA program in 1999. He was also appointed reporter for France on “intangibles and transfer pricing” for the annual International Fiscal Association conference held in Kyoto in 2007
• Forte compétence économique : prix de transfert (analyse des différentes problématiques, recherches de comparables, analyse de répartition de marge, etc.), évaluation d’incorporels (notamment de commercialisation ou de fabrication), relations financières (prêt intra-groupe et capitalisation, relations de prix de transfert dans les banques) et de manière générale, analyses économiques dans le cadre fiscal (évaluation d’actifs, crédit d’impôt recherche…).
• The pooling of expertise with additional partners in particular management consultant firms for optimizing the supply chain,Enhanced personalization of transfer pricing projects in accordance with the flexibility of the teams.