These measures, set to be included in the Finance Bill for 2024, are poised to strengthen our financial ecosystem and ensure fairness in taxation. Here's a rundown of the most significant highlights:

Lowering the Transfer Pricing Documentation Threshold:
To enhance transparency, the government plans to reduce the annual turnover threshold for multinational enterprises required to provide transfer pricing documentation. Currently set at EUR 400 million, this adjustment will broaden the scope of multinational entities subject to scrutiny.

Extending the Statute of Limitations:
The cross-border transfer of intangibles will be subject to an extended statute of limitations exceeding the current three-year timeframe. This measure aims to address potential tax evasion involving intangible assets and reinforce the effectiveness of our tax enforcement efforts.

Introducing "Tax Indignity" Penalty:
In an effort to deter tax fraud, taxpayers found guilty will face a specific penalty known as "tax indignity." This penalty will deny them any tax credits, serving as a strong disincentive for engaging in fraudulent activities and reinforcing the importance of compliance.

Additionally, the government has set ambitious goals to combat tax evasion in the coming years:

Increasing Tax Audits:
By 2027, the number of tax audits on private individuals, especially high-net-worth individuals, and the largest multinational enterprises will rise by 25%. This proactive approach will ensure a comprehensive examination of tax affairs, promoting fairness and accountability.

Establishing a Special Audit Team:
To tackle the most serious cases of international tax fraud, the government will create a dedicated audit team. This team will focus on complex instances, such as the utilization of foreign shell entities or trusts, to ensure robust action against illicit financial practices.

Advocating for Tax Transparency:
France aims to initiate international action to promote tax transparency on a global scale. The ultimate objective is for all tax authorities to have a comprehensive overview of taxpayers' assets worldwide. This step will foster cooperation among nations and contribute to curbing tax evasion effectively.

The government's commitment to combating fraud in public finances is unwavering. In the near future, they will unveil a comprehensive plan to counter all types of fraud, providing further details on these measures. We will keep you updated on any new developments as they unfold.

Stay tuned for more exciting news in transfer pricing and international taxation.