France: CbC Reporting Update and Legislation

The law firm Bird & Bird provides a great summary of the latest CbC reporting changes in France.

“Introduction of a Country by Country Transfer Pricing Reporting (CbCR) requirement

• For fiscal years beginning on or after January 1st, 2016, a country by country reporting requirement is established in order to implement Action 13 of the BEPS action plan adopted by the OECD.
• Fall into the scope of the CbCR requirement companies established in France which
  • draw up consolidated accounts, and
  • realize an annual consolidated turnover of at least €750 million, and
  • own or control, directly or indirectly, one or several legal entities established out of France or have branches abroad and
  • which are not owned by one or several legal entities situated in France and subject to such CbCR requirement, or established outside France and subject to a similar CbCR requirement pursuant to foreign legislation.
• Country by Country Transfer Pricing Reporting must be subscribed in dematerialized form within twelve months of the end of the financial year, must indicate the country by country apportionment of group profits as well as economic, accounting and tax aggregates, and finally information on the location and the activity of the group entities. The information to be communicated shall be specified by a decree to be published.
• The absence of filing will result in a fine up to €100,000.”

See the complete summary of the Finance Act (2016) provided by Bird & Bird here : http://www.twobirds.com/en/news/articles/2016/france/finance-act-for-2016-and-amended-finance-act-for-2015-company-taxation

Robert Robillard, Ph.D., CPA, CGA, MBA, M.Sc. Econ.
Senior Partner, DRTP Consulting Inc.
514-742-8086; robertrobillard “at” drtp.ca
www.drtp.ca

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