French Court Holds Insufficient Remuneration for Brand Development Considered Transfer of Profits to Foreign Parent

A recent decision of the Administrative Court of Appeal of Paris has been published concerning transfer pricing issues for costs incurred by a French company in developing the brand of its foreign parent. The case involved the French company Ferragamo France, which is indirectly owned by the Italian company Salvatore Ferragamo Spa through a Dutch Ferragamo International BV. Ferragamo France is engaged in the retail trade of shoes, leather goods, and luxury accessories and distributes, in sto…