The French tax authorities have announced the creation of a new program—Mission d’expertise juridique et économique internationale (MEJEI) – which will be responsible for both advance pricing arrangements (APAs) and mutual agreement procedures (MAPs). Previously, APAs and MAPs were the responsibilities of two separate offices within the French government.
Historically, the two programs were viewed as not cooperating with each other—at times, to the detriment of taxpayers. By bringing the two programs together the tax authorities should be able to achieve a greater degree of cooperation between the relevant personnel, thereby creating more certainty and lower compliance costs for taxpayers.
In a similar way to the current treatment of APAs and MAPs in the United States (i.e., within the IRS’s Advance Pricing and Mutual Agreement (APMA) program), France’s MEJEI program:
- Will combine under one roof and within one team responsibility for both APAs and MAPs; and
- Will be able to benefit from the efficiencies and synergies of dealing with these similar programs.
The introduction of the new program will therefore have advantages for both taxpayers and the tax administration.
