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French APAs

 
Laurence Delorme 1 Transfer Pricing Partner with Landwell & Associés and Stephane Delliot Head of Tax at Shell France offer some insight into French APAs
 
In a rapidly changing environment and with the revived need for greater internal transparency and enhanced external visibility the tax function is being more and more scrutinised on its contribution towards the overall risk management of companies in their attempt to enhance stakeholders' value.
 
Transfer pricing is a traditional area where the tax function has to cope with the tightening up of national legislations throughout the globe and the correlative emphasis on the documentation effort obligation that is being required not always on a consistent basis by the respective fiscal authorities.
 
This increased level of documentation...

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