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French tax draft confuses advisers

May 12, 2010

A draft bulletin officiel des impôts released by the French tax authorities, intended to help taxpayers and practitioners understand the changes to transfer pricing rules in the country has instead deepened the confusion.

The draft offers no real changes in light of the text of the law. The penalty regime, for all group operations starting from financial years beginning with 2010, remains the same with fines from €10,000 [$12,692] to 5% of the amount in dispute if no documentation at all or no appropriate documentation is provided at the time of a tax audit. The text confirms that the 30 days time frame in which to provide the information can be extended by an additional 30 days at the French tax authorities’ discretion.

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