Congrats to our firm from France, Cara Avocats, that finalizes an out-of-court agreement between France and Spain for a major pharmaceutical group. The procedure that started in 2021, the Cara Avocats team, closed the agreement leading to the elimination of double taxation suffered by a French pharmaceutical group.

According to the Cara Avocats team, “The particularity of this procedure was that the French tax authorities had corrected the transfer prices applied between the French supplier and its subsidiary for one financial year, and that its Spanish counterpart, following another local tax audit, had adjusted the same flows for another year. It was therefore up to us to reconcile the two approaches and find common ground that would satisfy the interests of the group, the individual companies, and the treasury of both countries.
This procedure, commonly known as the "mutual agreement procedure for the elimination of double taxation" (or "MAP" in English jargon) requires regular monitoring and enhanced cooperation between the taxpayer and the authorities of both countries.”

The Cara Avocats team is happy to help their client and proud to contribute to the client's TX security.