Lowering of the Documentation Threshold: Reduction of the threshold from 400 million to 150 million euros for the documentation of transfer prices, applicable to financial years starting after January 1, 2024. Increase in Fines: Fines for non-presentation of documentation increase from €10,000 to €50,000. Extension of the Limitation Period for Transfers of Intangibles: Extension from 3 to 6 years for the audit of cross-border transfers of difficult-to-value intangibles, allowing tax authorities to use post-transfer profits to assess their value.

Transfer Pricing Updates in the 2024 Finance Law in France: Reduced Documentation Threshold: The turnover threshold for transfer pricing documentation is lowered from 400 million to 150 million euros for fiscal years starting after January 1, 2024. Higher Fines for Non-Compliance : Fines increase from €10,000 to €50,000 for failing to provide documentation. Extended Audit Period for Intangible Transfers: The statute of limitations for auditing cross-border transfers of hard-to-value intangibles extends from 3 to 6 years, allowing tax authorities to use post-transfer profits for valuation.