France Updates Guidance on Mutual Agreement Procedures and Advance Pricing Agreements

The French tax authority has announced the publication of updated guidance on Mutual Agreement Procedures (MAP) and Advance Pricing Agreements (APA). The updated guidance provides clarifications following a public consultation held in 2025, and includes the following three main updates:

Section 110 of BOI-INT-DG-20-30-10

The tax authority now officially treats the summary letter of taxes and penalties (sent by the Large Business Tax Compliance Service) as an "administrative measure" resu…