France Launches New Centralized Transfer Pricing Program French Tax authorities recently launched a new transfer pricing program - Mission d’expertise juridique et économique internationale (MEJEI). This program will be jointly responsible for both Advance Pricing Arrangements (APAs) and Mutual Agreement Procedures (MAPs), reports Nair & Co.’s International Tax team. Formerly, APAs and MAPs were separately handled by Direction générale des finances publiques (Bureau CF3) and Direction de la legislation fiscale (Bureau E1), respectively, with little collaboration and frequent inconvenience to the affected parties. The new French centralized program – MEJEI can be compared to the current treatment of APAs and MAPs in the United States. Under this new program, one team will be responsible for both APAs and MAPs. Further, similar programs are expected to be carried out more efficiently and effectively. Nair & Co.’s International Tax team anticipates the new MEJEI program to be beneficial for taxpayers. Reasons for launching the MEJEI include:
Lack of cooperation between Bureau CF3 and Bureau E1
Taxpayers’ exposure to certain disadvantages arising out of lack of operational synergies between the above bureaus
Incompatible case resolutions, in certain situations, by the above bureau
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French Tax authorities recently launched a new transfer pricing program - Mission d’expertise juridique et économique internationale (MEJEI)...