Case Study 7: Audit Defense and Litigation (France)
WTP Advisors prepared transfer pricing analysis and related filings in response to an assessment from the French tax authorities (FTA) concerning patent royalties paid by a French subsidiary to its Dutch parent company. The FTA acknowledged that they utilized secret comparables in reaching their initial assessment, but our research and our client’s industry knowledge and history of acquisitions within the industry led us to conclude that the FTA failed to identify critical factors in their transfer pricing comparables analysis. We assisted French counsel in the preparation of an appeal concerning the transfer pricing for the underlying licenses