• Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 2/20/2014

France - New program jointly responsible for APAs, MAPs 

February 20: The French tax authorities this week announced the creation of a new program—Mission d’expertise juridique et économique internationale (MEJEI)—that 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.

  • Bureau CF3 of the Direction générale des finances publiques was responsible for APAs.
  • Bureau E1 of the Direction de la legislation fiscale was responsible for MAPs.

Historically, the two programs were viewed as not cooperating with each other—at times, to the detriment of taxpayers. For example, the two programs did not always cooperate concerning the roll-back of APAs and, at times, achieved inconsistent case resolutions.

New centralized program, team approach

Similar 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
  • Will be able to benefit from the efficiencies and synergies of dealing with these similar programs

KPMG observation

Transfer pricing professionals in France expect that taxpayers subject to the jurisdiction of the MEJEI program will benefit from additional resources to manage existing cases and new requests.

For more information, contact a tax professional with KPMG’s Global Transfer Pricing Services group (Fidal*) in Paris:

Pascal Luquet

+ 33 1 55 68 15 22

Olivier Kiet

+ 33 1 55 68 16 15

Kate Noakes

+ 33 1 55 68 16 57

Xavier Sotillos Jaime

+33 1 55 68 14 85

François Vincent

+33 1 46 24 30 30

*Fidal is an independent legal entity that is separate from KPMG International and its member firms.

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Washington, DC 20006.


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