France’s tax authority reported a significant rise in recovered unpaid taxes for 2024, led by transfer pricing and other international tax adjustments. According to the Directorate General of Public Finances, business tax recoveries through audits grew by 23%, reaching €5.2 billion. Transfer pricing cases accounted for 64% of that total—around €3.3 billion. The agency argued that this revenue is a result of stronger audits conducted on how multinational companies value transactions between related entities, leading often to profit shifting toward lower-tax countries.
To access the official reporting, click here.
On July 23, 2025 France’s General Directorate of Public Finance published guidance guiding the implementation of OECD’s Pillar One Amount B principles. The document outlines how France will handle the scope of transactions and methods for adopting transfer prices under Amount B. France will honor results based on Amount B for fiscal years starting on or after January 1, but only when applied by a jurisdiction that has a tax treaty with France and qualifies as a “covered jurisdiction.” As of June 30, no such jurisdictions have adopted Amount B. The guidance also confirms that Amount B outcomes are seen as valid estimates of arm’s length pricing, but if used by non-covered jurisdictions, they have no legal weight in France.