Profit Shifting and Comparability: The French Supreme Administrative Court Provides Useful Clarification on Functional Analysis and the Concept of Routine Entity

Journal

Author

Douvier, P-J.; Gocer, S.

Country

France

Published Date

1 March 2022

Issue

International Transfer Pricing Journal 2022 (Volume 29), No. 2

DOI

https://doi.org/10.59403/3p89ntg

Document

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In two decisions of 4 October 2021 (SAS RKS and SAS Holding SKF France), the French Supreme Administrative Court (Conseil d’Etat) has confirmed the need to conduct a detailed and precise functional analysis that cannot be limited to the simplistic opposition between the concepts of principal entrepreneur and routine entity.

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Profit Shifting and Comparability: The French Supreme Administrative Court Provides Useful Clarification on Functional Analysis and the Concept of Routine Entity