en

English Français
Careers
Discover us Team Our network Diversity CSR
Corporate M&A Transaction Tax Venture & Growth Capital International Tax Corporate Law – Governance Tax Transformation Tax Advisory Additional Expertises Transfer Pricing
Healthcare
Technology
Real Estate
Infrastructure & Energy
Aeronautics & Defence
Agriculture & Food
Mobility
Retail
Media & Entertainment
Education
Luxury & Cosmetics
B2B Services
Eight Advisory Avocats Paris Eight Advisory Avocats Lyon
News Awards

HomeTransfer Pricing

Transfer Pricing

Présentation of our expertise

Eight Advisory Avocats assists companies of all sizes operating internationally in the design, documentation and defense of their transfer pricing policies.

Our team works alongside tax, finance and legal departments to design intercompany models that comply with regulatory requirements aligned with the group’s value creation and operational model.

For international cross-border projects, we work in relation with our tax correspondents network, which allows us to cover more than 50 jurisdictions.

Our support

We assist our clients with all their transfer pricing issues, from designing and documenting their intercompany policies to valuing and defending them. Our expertise covers the entire tax and operational lifecycle of companies, from initial structuring to tax audit management.

Structuring and modelling of transfer pricing policies

  • Functional analyses and determination of the most appropriate transfer pricing methods (CUP, cost-plus, profit split, TNMM, etc.)
  • Design and modelling of transfer pricing policies aligned with OECD Guidelines, local regulations and the group’s business model
  • DEMPE analyses to assess and allocate functions, assets and risks related to intangible assets

Economic analyses and valuation

  • Preparation of comparability studies and benchmarking analyses (cost-plus or TNMM approaches)
  • Benchmarking of royalty rates, intercompany interest rates and service fees using the CUP method
  • Tax valuation of intangible assets, companies and shareholdings in the context of restructurings or transactions

Documentation and compliance

  • Preparation and update of transfer pricing documentation (Local File and Master File) in accordance with French or foreign regulations
  • Critical review of existing documentation and identification of potential tax risks
  • Documentation compliance following organizational or regulatory changes (restructurings, new flows, new jurisdictions)

Tax audits, litigations and mutual agreement procedures

  • Assistance during tax audits involving transfer pricing matters
  • Negotiation and follow-up of Advance Pricing Agreements (unilateral, bilateral or multilateral)
  • Management of Mutual Agreement Procedures (MAPs) and international dispute resolution processes

Transactional and post-deal integration

  • Design and review of transfer pricing policies and compliance in the context of M&As, carve-out and post-acquisition integration projects
  • Transfer pricing review of valuations and purchase price allocations (PPAs) and related tax implications
  • Harmonization and adjustment of intercompany remuneration models following reorganizations or intra-group financing arrangements

Our Team

Team

Hugo Larpin

Director

Transfer Pricing

Votre message a bien été envoyé
Thank you, your application has been sent

What is the subject of your request?

  • General questions
  • Jobs
  • Information for the press

Specify your request

Choose an office

Application

Unsolicited application

Specify your request