Statement of practice on cross-border dispute resolution - France significantly improves tax security for international transactions

The author analyses the extensive and detailed Statement of Practice, issued by the French tax authorities on 23 February 2006, which integrates the mutual agreement procedures provided for by Art. 25 of the OECD Model Convention and the EC Arbitration Convention of 23 July 1990. The Statement of Practice is of great significance for taxpayers, in particular, with regard to transfer pricing reassessments.