Transfer pricing briefing for January 2014

As well as wishing everyone a successful 2014 I would like to begin with updates to some of the recent stories in these transfer pricing briefings. First to France where on 29 December the Constitutional Court ruled that some of the measures of the recent Finance Bill are incompatible with the French constitution. This affects the new requirement that transfers of labour functions and risks to a related company outside France must be justified as being at arm’s length (see ‘Transfer pricing briefing for December’). It remains to be seen whether amendments will be made to accommodate the measure within constitutional limits or whether it will now be abandoned.

Meanwhile in...