Management fees: how to secure them

Updated March 2026 - management fees are not prohibited. On the other hand, they must be based on real services, usefulness for the company being invoiced, a defensible price and proofs. This is where the tax risk comes into play.

To complete, also see Associate current account, Financial management and Tax or social question.

• ▸the service actually exists;
• ▸it provides an identifiable service to the invoiced company;
• ▸the price is consistent;
• ▸the documentation is sufficient.

What weakens the case

• ▸a vague agreement;
• ▸invoices that are too generic;
• ▸the absence of deliverables or elements of proof;
• ▸a fixed amount unrelated to the services rendered;
• ▸confusion between group management and service provided to a subsidiary.

Hayot Expertise advice: a defensible management fee is built before the invoice. It is necessary to define the service, the calculation key and the proof of utility.

We can help you reread the agreements, supporting documents and the economic logic of the system.

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In 2026, the security of management fees is based on a clear triptych: substance, price, documentation.

Do you want to check if your management fees are defensible in the event of an audit? We can support you.

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(Official sources: article 39 of the CGI, BOFiP on the deduction of charges and SME transfer pricing guide)