The bilateral tax conventions entered into by France stipulate that any individual or legal entity resident of either State which is party to the convention may apply for a MAP.

Consequently, if you are liable, in France or abroad, to tax owing to your tax residence, headquarters or any other similar criterion, you can apply for a MAP under the bilateral tax convention signed between France and the other State.

When only EU Member States are concerned, you can also apply on the ground of Council Directive (EU) 2017/1852 of 10 October 2017 on tax dispute resolution mechanisms in the European Union. For transfer pricing matter only, companies can also apply using the EU Convention (90/463/EEC) on the elimination of double taxation in connection with the adjustment of profits of associated enterprises.