Transfer pricing in stablecoin issuer groups
For a French company within a stablecoin issuer group, the useful decision is which activity it charges for, to which entity and with what evidence. The name on a token does not describe the entire economic chain. BECTRA’s proposed approach starts with observable operations and decisions before negotiating a royalty or mark-up.
Delineate dealings with overseas group companies
French tax guidance addresses cross-border dealings between associated enterprises. It calls for an analysis of functions, risks, assets and resources before selecting the pricing method; the BOFiP guidance dated 10 December 2025 refers to Article 57 of the French Tax Code. Keep this tax framework separate from the accounting basis and regulatory permissions.
In the proposed file, use a separate entry for each dealing: software development, technical operations, customer support, distribution or financing. Identify the recipient, actual deliverable, period, contract, invoice and entries on both sides. A blockchain transaction can locate an operation; it does not, by itself, explain work performed between companies.
Assess the legality of each activity and settlement separately in the countries concerned, including issuer status, providers’ scope and any exchange-control constraints. A tax conclusion about a price does not authorise stablecoin issuance or transfers. Without defined countries and a payment route, the regulatory conclusion remains open.
Establish who actually makes the decisions
OECD Guidelines 2022 paragraphs 1.64–1.65 distinguish financial capacity from control over risk, involving decisions actually exercised. Paragraph 6.42 explains that legal ownership of an intangible alone does not allocate all its returns to the owner.
BECTRA’s proposed application: for each material decision, identify the decision-maker, qualified staff, information received and dated evidence.
Issuance — Who can change an issuance procedure?
Incident — Who accepts a technical exception or initiates a response?
Budget — Who approves development spending?
Compare the evidence with the contract, without inferring a tax role merely from possession of keys.
This map prepares the detailed analyses of reserve income, licences and compliance. It does not settle those separate subjects. Where several teams contribute, document their distinct contributions before describing one entity as a routine operator.
Worked example: explain an invoice before defending its mark-up
Hypothetical case: a French subsidiary provides technical services to an overseas associated company. Directly attributable costs are EUR600,000; shared expenses allocated using a documented key are EUR100,000. An assumed 8% mark-up produces an invoice of EUR756,000: EUR700,000 × 1.08. The activity’s result would be EUR56,000 before any other relevant items.
The 8% figure is solely an illustration, not an accepted rate or comparable. Before using any such calculation, support the cost perimeter, benefit received and appropriate remuneration for the activity actually delineated. If the subsidiary itself decides investments and controls significant risks, reconsider the assumption that it is a limited-return service provider.
Reconciliation test: the recipient should identify the same service and period in its own records. An invoice difference, missing deliverable or excluded cost needs an accountable owner and a recorded resolution; settlement in tokens does not resolve these issues.
BECTRA deliverable: a dealings and decisions matrix
Build a matrix connecting each dealing to its contract, decision-makers, operational records, costs and proposed pricing method. Attach a reconciliation of reciprocal balances and an open-issues register. Evidence may include technical tickets, approved budgets, meeting records and acceptance records; select documents that actually explain the service.
The finance team should be able to decide whether the file is usable, a comparability analysis is needed or the facts contradict the contract. Retain explicit reservations for missing evidence, uncertain regulatory scope or insufficient support for a cost-allocation key. The deliverable does not turn assumptions into tax clearance.
Conclusion
For an issuer group, explaining dealings, contributions and decisions first reduces the risk of defending a price built on an inaccurately described activity. The numerical invoice comes next. Accounting classification, regulatory compliance and tax documentation remain distinct analyses that must be reconciled.
Further reading
Sources
Sources reviewed on 29 October 2026: French tax guidance dated 10 December 2025 and OECD Guidelines 2022. Case and file methodology proposed by BECTRA; the example validates no tax mark-up.
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