As regards transfer price for a distribution center the Service of Anticipated Decisions has taken an interesting ruling (n° 600.445 dd. 06.03.2007) by considering that comply with the principle of fair competition a chargeback (or reinvoicing) at 105% of the running costs {accounts 60 to 64 of the PCMN (1) } other than the outlays which will be reinvoiced at 100%, a chargeback at 100% of the net financial expenses (either the positive difference between accounts 65 and 75 of the PCMN) and a chargeback at 100% of the net exceptional chargess (or the positive difference between accounts 66 and 76 of the PCMN).

Please remember that the Courts as well as the tax administration consider such a ruling is only valid for the taxpayer who has asked it. It would consequently be hazardous to apply as such this ruling without asking one considering your specificities.

Stephen G Hürner
Tax Adviser

(1) PCMN : MINIMUM LEGAL STANDARDIZED CHART OF ACCOUNTS