Conversion, liquidity and transaction fees
A French subsidiary using a cross-border group payment service needs an invoice explaining both the service and its price. The stablecoin amount transferred does not by itself establish the cost base for a service charge. Separate third-party expenditure, the service centre’s own work and the risks it actually assumes.
Reconstruct the price before selecting a mark-up
BECTRA’s working method records the starting amount and currency, token and network, entry conversion, transfer, exit conversion, amount received, platform and network fees, and group remuneration. Timestamp exchange rates. Reconcile any difference to explicit fees, spread or market movement.
The arm’s length analysis examines functions, assets, risks and comparable circumstances. Labelling expenditure “external” does not establish that it should be passed through without a mark-up.
Establish what the group provider does
For an entity acting only as an intermediary, OECD paragraph 7.34 addresses remuneration for the intermediary function rather than mechanically marking up the underlying purchased service. This does not automatically exclude every third-party cost. Providing liquidity, guaranteeing a quote or assuming risk requires separate analysis.
Worked example for a French subsidiary
Hypothetical documented costs are EUR 120 for conversion, EUR 20 for network execution and EUR 200 of attributable in-house service costs. An illustrative 8% mark-up on EUR 200 produces EUR 16 and a total charge of EUR 356: 120 + 20 + 200 + 16. The 8% assumption illustrates arithmetic; it is not an established arm’s length rate.
Without evidence supporting pass-through treatment of EUR 140, that calculation does not substantiate the price. Obtain contracts, third-party invoices, allocation support and the functional analysis. A percentage commission on transferred value also needs economic justification.
Deliverable and decision
A BECTRA transaction record can reconcile the group invoice, external supporting documents and the amount received. Each line identifies the beneficiary, service, cost base, pricing method and missing evidence. The finance director can identify supported charges and items requiring completion. VAT treatment and regulatory permissibility require separate assessment.
Framework reviewed on 28 October 2026
The French administrative guidance cited is the version of BOI-BIC-BASE-80-10-10 published on 10 December 2025. The OECD Guidelines provide a separate analytical framework. The official Chapter VII consultation page still describes proposals, with a meeting announced for 9 November 2026; this article does not treat them as adopted rules.
Conclusion
Execution evidence explains the payment route. Transfer pricing analysis must also explain the charge.
Further reading
Sources
Sources reviewed on 28 October 2026. Hypothetical worked example; procedure and deliverable proposed by BECTRA.
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