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France vs SAS Roger Vivier: JUDGMENT

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France vs SAS Roger Vivier: JUDGMENT

Case Information

  • Court: Cour Administrative d’Appel de Paris, 9th Chamber
  • Case Number: 23PA01130
  • Applicant: SAS Roger Vivier Paris
  • Defendant: French Ministry for the Economy, Finance, and Industrial and Digital Sovereignty
  • Judgment Date: 13 December 2024

The Cour Administrative d’Appel de Paris upheld significant portions of the tax adjustments imposed on SAS Roger Vivier Paris (RVP) for the years 2012–2014. The French tax authorities argued that RVP, as part of a group involving foreign parent entities and related companies, engaged in practices leading to profit transfers inconsistent with the arm’s length principle as outlined in Article 57 of the French General Tax Code. The adjustments addressed insufficient re-invoicing for brand promotion expenses, failure to apply appropriate margins, and substantial discounts on unsold inventory returned to its supplier, Tod’s.

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File Size: 153 KB
Categories: France
Tags: ALP, Arms Length Principle, International Tax, Tax Compliance, TNMM, Transactional Net Margin Method, Transfer Pricing
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Dimension Transfer Pricing International Taxation South African Tax Law
Jurisdictional audience Global audience, covers all jurisdictions Global audience, covers all jurisdictions South Africa specific, relevant to SADC region
Ideal for TP managers, advisors, in-house tax teams, analysts moving into TP Advisors and managers dealing with cross-border rules, treaties, planning Practitioners working with the SA Income Tax Act, cases, compliance
Core focus Methods, comparables, DEMPE, documentation, audits, dispute defence Treaties, source vs residence, anti-avoidance, PE, relief from double tax Statutory interpretation, case law, assessments, objections, local practice
Primary tools OECD TP Guidelines, UN Manual, BEPS Actions 8–10, 13, case law OECD and UN Models, MLI, BEPS 1.0 and 2.0, domestic rules, cases Income Tax Act, SARS practice notes, Tax Administration Act, SA cases
Assessment style Case-based assignments, file reviews, short written defences Problem questions, treaty interpretation, position papers Problem questions, statutory analysis, case commentary
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Dimension Conducting a Transfer Pricing Trial Effectively Managing Tax Teams Indirect Taxation Tax Risk Management
Jurisdictional audience Global audience Global audience Global audience, with local adaptation Global audience
Ideal for In-house tax, TP managers, litigators, advisors preparing for audits, ADR, trial Heads of tax, managers, team leads, controllers, emerging leaders VAT, GST, customs, finance managers, AP, AR, compliance specialists Tax managers, risk officers, controllers, advisors building governance
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Delivery mode Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study Online, live sessions plus guided self-study
Duration 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time 16 weeks, part-time
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Prerequisites TP fundamentals recommended Supervisory experience helpful Basic VAT knowledge helpful General tax experience helpful
Pathway Progress to PG Certificate in Transfer Pricing Progress to Mechanics of Leading Tax Teams, PG Certificate (leadership) Progress to PG programmes, International Tax or SA Tax Law Progress to PG Certificate in International Taxation or Transfer Pricing
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5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected