Transfer Pricing and International Taxation

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SFM Conseil assists domestic and international businesses in defining, implementing and defending their transfer pricing policies

Transfer pricing is a necessary and legitimate part of the commercial life of multinational companies in a global economy. When setting their transfer prices, groups make choices that have an immediate and direct impact on the tax base of the countries involved in the transactions.

As a result, transfer pricing is receiving increasing attention from administrations around the world. They therefore represent a major challenge, both in terms of tax and customs revenues, and in terms of foreign currency flows between the Moroccan subsidiaries of multinationals and their parent or sister companies based abroad.

Aware of this challenge, the Moroccan legislator has established a transfer pricing framework, both in domestic law and in the many double taxation agreements signed by the Kingdom. Multinational companies are faced with the emergence of more detailed and demanding transfer pricing regulations.

Applying an arm's length price to transactions between dependent companies is a tricky business. This requires methodology, documentation, functional analysis of transactions, etc. The Tax Services team has a wealth of experience in this field, and brings its knowledge of international taxation to bear on the projects of multinational companies :

  • Definition and implementation of transfer pricing policies
  • Securing transfer pricing policies
  • Risk diagnosis
  • Prevention and resolution of double taxation
  • International mobility program tax cost management, etc.

The Tax Services team also advises foreign groups setting up in Morocco on how to optimize shareholding in the Moroccan subsidiary, taking into account the impact of international tax treaties while ensuring compliance with Moroccan tax requirements.