Arcotia Hatsidimitris - International Tax Dialogue

ANNEX C – 97
• when there are several French companies involved that need to be audited in the same
timeframe.
Coordinating the transfer pricing audit team if any
For the national and international tax audit directorate (DVNI), a transfer pricing audit team can
be composed of 3 or 4 persons: one general tax auditor, one or two transfer pricing expert(s) (it
depends on the nature and complexity of the case) and, generally, one IT accounting auditor. The
general tax auditor is the team leader.
The co-ordination of the whole team is an important point.
The transfer pricing team leader must synchronise the team schedule where the different auditors
(general, expert and IT accounting) have many other companies to audit in the same time.
Therefore, he has to ensure that the transfer pricing expert gathers all information needed to
prepare the first meeting with the taxpayer.
During the tax audit, the team leader has to check the transfer pricing issues with the transfer
pricing expert and to take care of the consequences of transfer pricing adjustments on other tax
adjustments and vice versa. He has to follow up the different issues in order to finalise both the
process of general audit and transfer pricing audit in a same timeframe.
The main objectives of the preparing phase by the audit team are:
• more effective management of tax issues in a short time;
• shorten examination processes both for revenue authorities and for taxpayers: audit teams
can achieve efficient and effective results if proper planning occurs and processes are welldefined;
• increase the efficiency and effectiveness of discussions between taxpayers and team audits
on technical and complex issues.
Good preparation of the transfer pricing team audit can also contribute to:
• a productive relationship;
• improving the understanding by the general auditor of the transfer pricing audit methodology
for future audits;
• inform the general auditor on issues linked to the transfer pricing ones and the potential
consequences of the transfer pricing adjustment on other taxes or the potential consequences
of tax adjustments on transfer pricing ones.
Gathering the best information
Before the audit, the tax audit services gather the most comprehensive information they can get in
order to get a good idea of the company’s environment and in particular the relations it has with
associated companies and the transactions it entered into.
DEALING EFFECTIVELY WITH THE CHALLENGES OF TRANSFER PRICING © OECD 2012