CRA Principal, Alberto Pluviano, reviews a report published by the French Ministry of Finance that analyzes the technical issues related to transfer pricing regulation in the French system compared with other countries and proposes new measures that would tighten the French transfer pricing regulations. The report also includes comments regarding permanent establishment issues.
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One of the most common analyses in transfer pricing is on the cusp of being overhauled at a global level. This pending change has the potential to impact many...