French International Tax Audits Brought in €5.2 Billion

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This article shows why transfer pricing disputes continue to be one of the leading international tax issues, and why a taxpayer must focus on documenting and complying with transfer pricing regulations internationally.

France Reports Major Spike in Recovered Taxes, Driven by Transfer Pricing Audits

Issue:
TheIssue:
France’s tax authority (DGFiP) released new audit results showing a surge in recovered unpaid taxes, with transfer pricing and other international tax issues at the center. Authorities are increasingly targeting whether multinationals correctly price intercompany transactions or improperly shift profits abroad.

Present Result:

• €5.2 billion in business taxes were recovered in 2024 — a 23% increase from 2023.
• Transfer pricing audits accounted for 64% of the total, or about €3.3 billion, marking a significant rise in enforcement in cross-border arrangements.
• International-related audits overall increased 9% year over year.
• VAT audits improved to €303 million collected (up from €283 million), aided by enhanced fraud-detection tools, platform delistings, and stronger cross-border data sharing.
• Wealth tax audits also saw major growth: €197 million recovered, up 45% from 2023.

To-Dos / Expectations / Next Steps:

Businesses should ensure proper documentation for transfer pricing positions and cross-border arrangements to prepare for heightened audit risk.

Multinationals operating in France should expect continued aggressive scrutiny of transfer pricing policies, especially around profit allocation to affiliates.

Companies selling goods/services online should anticipate tightened VAT enforcement, including stricter platform oversight and data-driven interventions.

High-net-worth individuals face expanded wealth tax review, with the authority signalling more resources and tools devoted to this area.