French Guiana

GF Transfer Pricing

Apply French transfer-pricing law to businesses and permanent establishments in French Guiana during 2026. Covers the substantive article 57 profit adjustment, related-party evidence, the distinct annual 2257-SD declaration and master/local-file documentation tests, group extensions, deadlines and documentation sanctions. Use for Guyane related-party services, imports, loans, management fees, arm’s-length pricing, French transfer-pricing thresholds and audit documentation. Explains why a local entity below a financial threshold may still be caught through its group and why filing thresholds do not exempt its prices from substantive review. Includes recomputing adjustments and a reporting-boundary case. Special financial, intangible, APA, Amount B and country-by-country work requires separate current-law analysis.