GF Transfer Pricing

General reference only. This Guide is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

Who this applies to

French Guiana is within the French income/corporation-tax territory. It is not a foreign country for article 57 merely because goods cross the octroi or VAT border. Businesses in Guyane with controlled enterprises outside France must consider CGI article 57; corporations apply the relevant business-profit rules through the corporate framework. Mainland-to-Guyane transactions are not automatically international transfer pricing. DGFiP DOM guidance; BOI-IS-CHAMP-60-10-10 §20; CGI art.57.

Quick answer: test substantive prices, annual disclosure and audit documentation separately. Exemption from a filing threshold does not establish an acceptable price.

Rates, bands and thresholds

Obligation	Threshold and conditions	Official source
Substantive adjustment	Article 57 applies to indirect profit transfers to controlled/dependent enterprises abroad; no general turnover exemption in its text; privileged-tax or non-cooperative territory cases dispense with the dependency condition	CGI art.57
Annual 2257-SD	Annual turnover excluding tax or gross assets at least EUR 50 million, or qualifying majority ownership/control or tax-group extension; relevant foreign controlled transactions required	CGI art.223 quinquies B; BOFiP I §§1-20
Annual transaction reporting	Aggregate each nature of transaction; report above EUR 100,000, without netting income against expenses; the administrative no-filing tolerance uses transactions below EUR 100,000 by nature	BOFiP I §10, II-B §§100-140
Master/local-file audit documentation	Turnover excluding tax or gross assets at least EUR 150 million, or qualifying majority-parent/subsidiary or tax-group extension; applies to years opened from January 2024	LPF L13 AA; BOFiP I §§1-40
Annual filing deadline	Electronic declaration within six months after the statutory results-return deadline	CGI art.223 quinquies B; BOFiP §40
Audit production	Available at audit commencement; incomplete/non-production leads to notice normally allowing 30 days, subject to proper extension	LPF L13 AA III; BOFiP IV

A small local subsidiary can meet the parent test. Foreign legal entities with a French PE have specific threshold-at-entity/PE rules described in each source; do not test only branch turnover. Exactly EUR 100,000 is a boundary: the law's reporting trigger is “exceeds” while the administrative no-filing tolerance says “below”. Do not widen that tolerance to an automatic equal-to exclusion. BOFiP.

The base

Map direct/indirect control and common control, then identify actual goods, services, royalties, loans, guarantees, assets and linked arrangements. Article 57 reinstates profits transferred by increased/decreased purchase or sale prices or another means. For privileged-tax or non-cooperative counterparties do not insist on proving common control before examining the rule. The documentation-to-actual-conduct divergence in article 57 can create a rebuttable transfer presumption. CGI art.57.

Prepare a functional/comparability analysis: identify services actually delivered and their benefit, assets used, risk control, terms, reliable comparables, chosen method and adjustments. Reconcile the resulting remuneration to contracts, invoices and taxable results. A hypothetical cost-plus percentage in an example is not an official safe harbour. For documented groups retain the master file (group structure, value drivers, intangibles and financing) and local file (transactions, method, comparability, accounts/reconciliation and relevant rulings). The documentation does not replace transaction evidence. LPF L13 AA II; BOFiP II-III.

Boundary	Treatment
Below EUR 50 million and no group extension	Still test article 57; LPF L13 B information requests can apply
Annual declaration filed	Does not substitute for master/local file or underlying invoices
French mainland counterparty	Analyse ordinary deductibility, valuation and special domestic rules; do not assume “outside France” under art.57
Import price later adjusted	Examine customs value and octroi separately; income-tax adjustment does not automatically amend the customs declaration

BOFiP I §40, article 57, Customs valuation and transfer prices.

Deadlines and filing

Obtain the current 2257-SD and instructions from DGFiP form page. File electronically using the applicable professional/EDI procedure. Complete group activity and intangible information, local activity, gross flows by nature and foreign jurisdiction, and the principal pricing method for each category. An integrated group's parent files for each covered member; it is not simply one net group transaction figure. Reconcile to statutory accounts and retain the electronic acknowledgement. BOFiP II-III.

Audit documentation must exist by audit commencement; diary any formal production notice and its scope immediately. Request an extension in writing, with reasons and the requested duration; the total extension cannot exceed two months, and the authority must communicate its decision and any extended expiry date. BOFiP IV §630. LPF L13 B applies to smaller businesses on a suspected transfer, so maintain proportionate evidence even outside the full-file threshold. Country-by-country reporting under article 223 quinquies C and form 2258-SD is a separate group test; do not infer compliance from filing 2257. DGFiP CbCR.

Penalties and interest

For failure to answer or an incomplete answer to the required documentation notice, article 1735 ter permits, per audited year and according to severity, a fine up to the higher of 0.5% of the transactions left undocumented after notice and 5% of the relevant article-57 adjustments; it cannot be below EUR 50,000. A pricing-method disagreement alone is not a documentation failure. CGI art.1735 ter; BOFiP I §§10-100.

2257 late filing normally attracts EUR 150. Omissions/inaccuracies normally cost EUR 15 each, total minimum EUR 60 and maximum EUR 10,000; these sanctions are waived for a first infringement in the current calendar year and preceding three years if corrected spontaneously or within 30 days of the administration’s request, subject to the provision’s conditions. Tax, late interest and any substantive under-declaration penalty are separate. CGI art.1729 B; BOFiP II §160.

Cross-border points

A treaty corresponding adjustment or mutual agreement is not an automatic mirror entry. Check the actual applicable treaty, territorial clause and procedural deadline. Use gf-cross-border-tax. Do not treat Guyane's absence of VAT as absence of income tax, customs value or related-party scrutiny. Customs and foreign tax adjustments require separate reconciliation.

Two worked examples that recompute

Adjustment. A hypothetical Guyane business paid a controlled foreign supplier EUR 150,000 for an evidenced service worth EUR 120,000 under the selected reliable comparable method. Assuming article 57 applies, the add-back is EUR 30,000. Starting taxable profit EUR 70,000 becomes EUR 100,000 before other adjustments. No statutory 20% or 25% service margin is claimed.

name: Foreign service overcharge
inputs:
  paid: 150000
  independent_price: 120000
  starting_profit: 70000
steps:
  addback: paid-independent_price
  revised_profit: starting_profit+addback
expected:
  addback: 30000
  revised_profit: 100000

Threshold decision. Assume local turnover EUR 10 million and gross assets EUR 8 million, with a parent owning 100% and having EUR 160 million turnover. The local-only financial maximum is EUR 10 million, below both thresholds, but the majority-parent extension makes both the EUR 50 million disclosure and EUR 150 million documentation tests relevant. For 2257, assume two related-party service receipts of EUR 80,000 and EUR 60,000 of the same nature, plus EUR 20,000 service expenses. Aggregate receipts to EUR 140,000, crossing the receipts threshold by EUR 40,000. Expenses are a separate nature: do not net them from receipts, or add them to receipts to test one combined threshold. The net EUR 120,000 is not the reportable gross-receipts amount. Assume foreign controlled transactions and all other scope conditions. BOFiP §§110-120.

name: Aggregate receipts without netting separate charges
inputs:
  receipt_one: 80000
  receipt_two: 60000
  expenses: 20000
steps:
  gross_receipts: receipt_one+receipt_two
  net_difference: gross_receipts-expenses
  above_reporting_threshold: gross_receipts-100000
expected:
  gross_receipts: 140000
  net_difference: 120000
  above_reporting_threshold: 40000

Ask the client first

• Local legal form, tax regime, turnover and gross assets for the relevant year.
• Complete direct/indirect ownership and tax-group map with parent/subsidiary figures.
• Foreign controlled parties, jurisdictions and privileged/non-cooperative status.
• Gross flows by nature, contracts, actual services and allocation evidence.
• Pricing method, comparables, file version and reconciliation to accounts.
• Results-return deadline, audit notices and prior 2257/CbCR filings.

Sources

Source and text actually read	URL	Read on
CGI art.57, complete operative text including dependency exceptions and documentation presumption; “les bénéfices indirectement transférés”	https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048838867/	2026-11-11
BOFiP BOI-BIC-BASE-80-10-30, I-III, annual disclosure and gross aggregation; “aucune compensation entre des produits et des charges”	https://bofip.impots.gouv.fr/bofip/11462-PGP.html	2026-11-11
BOFiP BOI-BIC-BASE-80-10-40, I-IV, current December 2025 text and source-linked LPF L13 AA; “supérieur ou égal à 150 millions d’euros”	https://bofip.impots.gouv.fr/bofip/11463-PGP.html	2026-11-11
CGI art.1735 ter, complete current text; “ne peut être inférieur à 50 000 €”	https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000048838857	2026-11-11
BOFiP BOI-CF-INF-20-10-40, I-II sanctions and correction exception	https://bofip.impots.gouv.fr/bofip/10389-PGP.html	2026-11-11
DGFiP DOM income/company-tax territorial explanation, read for application to Guyane	https://www.impots.gouv.fr/professionnel/impots-professionnels-dom	2026-11-11
DGFiP CbCR page, read for separation of 2258 from 2257, not to assert a new threshold	https://www.impots.gouv.fr/la-declaration-pays-par-pays	2026-11-11

Not yet confirmed: special Amount B conditions, current APA forms, complete CbCR secondary-filing and exchange-country conditions. Those specialist jobs are out of scope; no exemption from them is asserted.