Managing transfer prices
The internationalisation of business leads groups to multiply their facilities throughout the world and business relations between them.
But each country has its own tax regulations, more or less constraining … and hope to preserve the amount of taxation.
Firms might be highly tempted to organise their activities and achieve their results where the tax pressure is weakest … but the calculation of the intragroup transfer price is strictly regulated, especially in the European Union and in France in particular.
Our primary concern is to optimize your overall effective rate of taxation; we help you to organise and secure the flows between your subsidiaries, in complying with the tax laws of the countries concerned.
Our answer
We assist you in all or part of the following assignments, depending on your requirements:
- identification and analysis of the various international flows, namely:
- use of intellectual property, know how
- centralization of supporting functions (administrative, financial, computer
services, marketing…)
- setting up of a cash flow unit
- purchase and sale of products
- determination of the legal constraints of each country on these flows
- analysis of the possible tax conventions between the countries concerned
- validation of the legal and tax feasability of existing or future international organisation patterns, securing and optimisation
- identification of the areas of tax risk
- setting up of adapted documents
- assistance in the event of an inspection by the Tax Authorities
The main fields of expertise concerned
Tax law
Contracts, Competition, Concentration & Distribution
And also…
Industrial and intellectual property
Your privileged interlocutors
In Lyon
Danièle SIBONI
In Paris
Christian CARUELLE
What you say about us...
« When I underwent a tax inspection, the French Authorities wanted to make an adjustment for non remuneration of our intellectual property through our subsidiaries. Thanks to Lamy Lexel, after analysis of all of our flows, we were able to prove that it was remunerated indirectly and thus escaped an important adjustment.”
The Finance Manager of an industrial group working in plastics technologies
