France introduced stricter documentation rules and expanded audit powers to reinforce transfer pricing oversight.
France has introduced new measures to reinforce the administration’s ability to detect and penalise abusive transfer pricing practices, following the publication of updates linked to Article 116 of Finance Act No. 2023-1322 of 29 December 2023 for 2024.
This announcement was made on 10 December 2025.
The reforms apply to multinational enterprises and focus on tightening documentation requirements and expanding the tax authority’s powers when reviewing transfers of intangible assets.
Under the new rules, the annual turnover threshold triggering the transfer pricing documentation obligation under Article L. 13 AA of the Tax Procedure Code (LPF) has been lowered to EUR 150 million (excluding VAT).
The minimum penalty for failing to provide this documentation has been increased to EUR 50,000, as set out in Article 1735 ter of the General Tax Code (CGI). The administration may also rely on the documentation provided by companies, which is now explicitly enforceable under CGI Article 57.
To ensure full application of OECD standards on the valuation of intangible assets, Article 116 also establishes a procedure for adjusting the value of hard-to-value intangibles, introduced via CGI Article 238 bis-0 I ter. In addition, the timeframe within which the tax authority may reassess such transfers is extended, as provided under LPF Article L. 171 B.
The law further creates an exception to the prohibition on repeating a tax audit, allowing a renewed examination when the extended reassessment period is invoked (LPF Article L. 51, 8°).
Earlier, France released its Finance Law for 2024 (Law no. 2023-1322) in the Official Gazette, along with the Constitutional Court’s review, affirming the constitutionality of key tax measures on 30 December 2023.
