Annex C: France

         International issues and transfer pricing in particular are a major audit target for the French tax administration (la Direction general des Finances publiques).          la Direction general des Finances publiques recognises that, due to the complexity of transfer pricing issues, transfer pricing audits require highly technical skills and special measures (training, documentation, private databases access).          For reasons of efficiency and legal certainty, in 2008, the Central Office decided that transfer pricing audits would be performed by national and inter-regional tax audit directorates. The large companies tax audit directorate (Direction des Vérifications Nationales et Internationales - DVNI) deals with the majority of transfer pricing cases as it is in charge of the audit of main groups and big companies.      