VOLUME 6, NUMBER 3 >>> NOVEMBER 2015

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1 VOLUME 6, NUMBER 3 >>> NOVEMBER 2015 Reproduced with permission from Transfer Pricing Forum, 06 TPTPFU 21, 11/24/15. Copyright 2015 by The Bureau of National Affairs, Inc. ( )

2 France Julien Monsenego Olswang, France While not referring explicitly to the arm slength principle of the OECD, the French practice of the transfer pricing rules are mostly in line with these OECD standards. For example, Section 57 of the French Tax Code (FTC), which is the main principle ruling transfer pricing in France, refers indirectly to the arm s-length concept, and the French Tax Authority (FTA), in a Transfer Pricing (TP) Guide for small and medium-sized enterprises (SMEs) 1, refers to the OECD terminology and hierarchy of methods even though it indicates that the taxpayer can choose any transfer pricing method to set intercompany prices._ It is also likely that French law and the FTA will rely more and more on the TPG, notably to incorporate the various principles set out in the recent final reports regarding BEPS. Therefore, while most of the situations described in the questions below are not yet targeted by French law or case-law, it may well be the case in the near future if French legislation is enacted to comply with the final reports recommendations. For instance, Actions 5 and 8 regarding IP Boxes will probably induce an amendment of the French Patent Box regime next year: similar changes could be implemented in the TP French framework under Actions 9 and/or 10. It is therefore likely that, directly or indirectly, amendments to French tax law will be made to include all or part of the final BEPS report, although to date there has been no publicized plan. The only and first forthcoming legislation that could start this process would be the country-by-country report implementation in France, which may occur as soon as the next Amended Tax Bill, for which a draft is to be issued and then voted on by the end of this calendar year. Issue One To what extent are the new emphasis on delineation of the actual transaction andthe focus on conduct in assessing intra-group contractslikely to force a change in the way MNEs structure and document their transfer pricing? In what way has the tax administration sought proof of genuine conduct in the past and how is this likely to change? Is the incidence of transfer pricing audits likely to go up? Most risk allocations (such as foreign exchange risk, collection risk and, more generally, all legal risks in relation with an activity) traditionally have been viewed under French law as depending on the nature of the contractual relationship between the parties (as long as the contractual provisions are in practice implemented), rather than the commercial rationality and/or the actual behaviour of the parties involved. That being said, in situations where the contractual and factual situations are not aligned, both the contractual and the factual approaches should be taken into account. Indeed, even though the French approach has traditionally been a legal one, in the event of a tax audit, if the contractual provisions have not been respected in practice, these provisions will be overlooked and not taken into account. Thus, it is crucial to align contractual risk allocation with the factual situation between parties, particularly when the parties are related. This requirement was illustrated recently in a Supreme Tax Court decision, namely the Zimmer case 2. In this case, the French Court ruled that a commissionaire acting in the ordinary course of its business cannot constitute a permanent establishment of its foreign principal in France. Indeed, based on the French Commerce Code provisions, a commissionaire acts in its own name and cannot conclude contracts in the name of its principal, which prevents the commissionaire from legally binding its principal. The legal and contractual approach has thus prevented any characterisation as a permanent establishment. However, the French Court also mentioned that if (i) the terms and conditions of the commissionaire s contract, or (ii) any factual element identified in the course of the examination of the case, allow the FTA to demonstrate that the commissionaire can take binding positions in the name of the principal, then the commissionaire would constitute a permanent establishment of its principal. This case-law put a strong emphasis on the need to substantiate contractual commitments by actual behaviour/conduct of the parties. In a business restructuring context, this decision illustrates the fact that the parties cannot inconsistently practice their 2 11/15 Copyright 2015 by The Bureau of National Affairs, Inc. TP FORUM ISSN

3 contractual commitments without risking a requalification of their relationship. It notably means that if a contractual situation is put in place, but the French party (e.g., a toll manufacturer bearing significant risks and or functions) actually takes on additional risks and/or functions, the FTA will be able to disregard the contractual situation to assess the French party s taxable profit based on the actual risk/function allocation (based on either of the two procedures listed under Question 3, below). In summary, for the time being, under French tax law the contractual situation should remain the starting point of any transfer pricing analysis. It is only in circumstances where the intent or the behaviour of the parties suggests that another arrangement has been made that the FTA will overrule the contract to requalify the transaction, using either the abuse of law procedure or, more likely, the simple requalification (these procedures are detailed below under Question 3). As to the notion of control, control of risk is still likely to be seen as the predominant criteria when assessing who is bearing the risk, while the financial capacity to bear the risk may be seen as more minor, as there are limited if no positive examples of this under French law at present. That being said, this situation is likely to change now that there is a new emphasis on delineation, and while the issue of control on intragroup transactions has already been key in previous tax audits and caselaw cases, it is likely to be even more so in the future, especially if any French law or FTA position is enacted in the future. This would also have an effect on transfer pricing audits, increasing both the volume of audits and the scrutiny of tax inspectors on risk allocation in related transactions. For instance, the French Supreme Court recently cited the notion of risk in an abuse of law case 3 to deny the interposition of a Dutch company that was a party to an operation. The Court noted that the risk the shareholders were bearing by using the Dutch company was no different than the risk they would have borne by directly being a party to the operation. The shareholders lack of control in the passive interposed Dutch company was another element taken into consideration to qualify the operation as an abuse of law, and conclude that the interposed company had no economic substance or role in this situation. Issue Two How will the new guidance on control of risk and financial capacity to assume risk affect the way in which multinational groups structure their operations? Does the tax administration have a history of challenging the level of returns to entities that only control risk and does the new guidance increase the likelihood of this? At what point in time would the taxpayer be required to have the financial capacity to assume risk? Before 2010, French TP legislation and guidance never explicitly commented on risk and function allocations, despite the fact that a complete description of such functions and risks as defined by the TPG was almost always requested from the FTA during tax audits, when operations involving TP concepts were at stake. In fact, before the new documentation requirements were enacted in 2010, the notion of functions and risks was only found in TP questionnaires provided by the FTA in the course of tax audits and in the FTA Guide mentioned above. In the Guide, references were made to the various types of risks to be taken into account in the course of the functional analysis (market risks, inventory risks, financial risks, industrial risks, etc.), and in its Appendix 2, providing a functional grid where these various risks are outlined. Since 2010, French tax law (article L 13 AA of the French Tax Procedure Code) directly refers to functions and risks, since the companies subject to the documentation requirements (mainly MNEs) must provide two sets of files, in line with the EU masterfile concept 4. Accordingly, functional analysis (including an accurate description of functions undertaken and risks borne) is now expected to be provided by the companies concerned in support of TP transactions. The level of risk borne should be mentioned both at the Master File and the Local File levels. Finally, since 2014, a new requirement under article 223 quinquies B of the FTC requires the filing of an annual TP form (No 2257-SD). However, to date, French administrative doctrine 5 has not detailed how the notion of risk should be reflected or developed in this concise form. In light of the recent BEPS developments, it can be anticipated that these requirements of disclosure of risks and functions will increase, and the French TP documentation elements to be provided contemporaneously or on demand (depending on the size of the French company and the group it belongs to) may be amended accordingly. The case-law has also provided some illustrations where the level of returns of entities were (notably) assessed based on the risks assumed by the parties, e.g., in situations where a gross margin was split between two parties, the French one bearing most of the functions and risks on the transaction 6. Issue Three To what extent and on what basis has the tax administration applied non-recognition rules in the past? How is the guidance on commercial rationality likely to affectthe tax administration s application? Do you expect it to lead to more occasions of non-recognition? To disregard situations where contractual arrangements and actual factual situations are not aligned, and apply the non-recognition rules (even if this terminology does not exist under French law), the FTA can use two different procedures: s The abuse of law procedure, enacted under article L 64 of the French Tax Procedure Code (FTPC), was defined by an extensive case-law for decades. Its definition was formally included in the law in Under this procedure, the FTA can rule out any legal arrangement constituting an abuse of law, and disregard the arrangement in order to restore its true nature. Such arrangements are considered either (a) fictitious, or (b) sound arrangements that are established to take advantage of the law in breach of the 11/15 Transfer Pricing Forum Bloomberg BNA ISSN

4 law s objectives, and are only motivated by a tax benefit that could not have been obtained without these arrangements. In both cases, there must be a determination of fraudulent intent on the part of the taxpayer? This procedure is strictly framed by specific procedure rules, so it remains exceptional and allows the taxpayer to benefit from higher guarantees (the procedure can only be applied by ranked inspectors and the case can be submitted to a Special Committee). Indeed, severe tax penalties are imposed on the tax evaded: an 80 percent penalty is applied against the main originator or beneficiary of the arrangements, plus interest for late payment. s The simple requalification can be implemented by the FTA pursuant to a normal tax audit when facing sound arrangements (as opposed to fictitious ones) that were incorrectly characterised by the taxpayer, whether wilfully or not. This situation will occur in cases where the tax and legal settings of a given operation will enable the FTA to requalify it, and consequently apply a different (less favourable) tax treatment. Using simple requalification rather than abuse of law procedure, the FTA will likely requalify a French commissionaire or toll manufacturer, for instance, and/or allocate more functions and risks to that party. This will happen in particular in situations whereby certain functions and/or risks once borne by the French party are then attributed to the related foreign party. Correspondingly, the FTA will attribute more of the total income deriving from the overall business to the French company. This practice has not been reviewed by French case law to date, but some cases should be submitted to French courts in a near future. However, French case law has already dealt with several recharacterisations of French subsidiaries into French permanent establishments of foreign companies, notably on the basis of converging clues, such as the level of risk and remuneration of the French subsidiary and the nature of the relationship between the companies 7. Recently, in the Bank of Scotland case 8, the French Supreme Court reviewed a set-up under which the shares in a French company were temporarily attributed to a U.K. bank by a U.S. parent company. This scheme allowed the U.K. bank to benefit from the reimbursement of French dividend tax credits ( avoir fiscal ) upon dividend distributions, which would not have been possible if the French company was still owned by the U.S. parent company at the time the dividends were paid. The French Court ruled out the scheme using the abuse of law procedure, and notably pointed out the lack of shareholder risk borne by the U.K. bank because the U.S. parent company was: s guaranteeing the payment of the dividends, in case the French company was unable to distribute them; s subject to a payment to the U.K. bank, in case the French dividend tax credits were not reimbursed by the FTA to the U.K. bank; s guaranteeing the financing of the French company allow this company to distribute dividends. Even though the notion of risk has not been emphasized as such in the Bank of Scotland decision, the motives are clearly inspired by this notion, as the guarantees highlighted above can be translated into financial risks borne (or not) by the parties involved in this requalified transaction. More recently, there has been a series of cases from the French Supreme Court under which excessive risk has been used to deny the deductibility of certain losses 9. In such cases, the judge or the FTA would qualify the risky operation as an abnormal act of management. Even if these cases were not in an intragroup context, the judge could assess a level of risk and determine if, in exceptional circumstances, the risks exceed certain reasonable limits, to the point where corporate interest is no longer respected, so that any loss arising from this excessive risk-taking position is denied. Such exceptional circumstances must be assessed based upon the specific context of the company, the purpose of the operation, the advice and guidance it has received from third parties, and the general economic situation of the industry the company is part of. That being said, the positive cases of the recognition of such excessive risk remain limited, and the same goes for the ability of the judge or the FTA to challenge the management of a company s business under this notion. Based on the current French rules of requalification, it should be noted that, legally speaking, the FTA still needs to use the procedure of requalification or simple requalification, and will not be able to simply disregard a delineated transaction without using the applicable procedure. In even more exceptional circumstances the FTA could use the French CFC rules to deny the existence of an interposed passive company, but again, these cases are rarely seen in practice. The mere fact that the OECD TPG provide for such an ability will not directly enable the FTA to avoid these procedures, and only a change under French tax law (for instance, including the TPG s position) would allow this situation, and that would be within the limits of the French constitutional rules, which can be rather strict. A more direct way to achieve the objectives of the revised TPG could be to simply allocate a global profit depending on the added value of each party, rather than literally requalifying the transaction. We will certainly see in the future whether the FTC will use new legislation or will adapt its position during tax audits to the notion of added value. Julien Monsenego is a Partner in Tax Law at Olswang France LLP in Paris. He may be contacted at: NOTES 1 Les prix de transfert Guide à l usage des PME - Transfer Pricing Guide for small and mid-size enterprises - Direction Générale des Impôts (November 2006). 2 Supreme Tax Court (Conseil d Etat), March 31, 2010, Number and Number French Supreme Court, May 11, 2015, No , SA Natixis. 4 Code of Conduct on transfer pricing documentation for associated enterprises in the EU. 5 BOI-BIC-BASE , n 410 and following paragraphs. 6 Administrative Appeal Court of Bordeaux, December 8, 2005, No , Corail, French Supreme Court, April 9, 2014, No , Sopebsa. 4 11/15 Copyright 2015 by The Bureau of National Affairs, Inc. TP FORUM ISSN

5 7 Supreme Court, June 20, 2003, No Interhome AG, quoted above, and the aforementioned Zimmer case. 8 French Supreme Court, December 29, 2006, No , Bank of Scotland. 9 French Supreme Court, April , No , Legeps, and June 11, 2014, No , Fralsen Holding. 11/15 Transfer Pricing Forum Bloomberg BNA ISSN

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