The bilateral APA 

The bilateral APA is an agreement provided for by bilateral tax conventions.

This arrangement should be your first choice if you are looking for the utmost legal certainty as it is negotiated and executed between the competent authorities of both States dealing with intra-group transactions.

The unilateral APA 

French regulations provide for this type of arrangement.

It is requested for instance if there are intra-group transactions with a large number of countries or when the Country counterparty to the transaction does not have an APA program.

Unlike the bilateral APA, the unilateral APA is only signed by France and your company. As a result, there is no legal certainty in the other State.

It should be noted that unilateral arrangements executed by Member States are now subject to spontaneous and compulsory information exchange within the EU and OECD.

This means that the States concerned by your intra-group transactions will be aware of the arrangements signed by France.

Updated DINR PRO 13/02/2025