FRANCE: COUNTRY-BY-COUNTRY REPORTING; BEPS PROVISIONS

The French Finance Minister, in an October 2015 press release, welcomed the agreement reached by the EU Finance Ministers on the introduction of provisions for the automatic exchange of information on cross-border tax rulings and the publication of the OECD reports on base erosion and profit shifting (BEPS).

The French Finance Minister further said that French tax law is, in certain respects, already in line with the “highest” international standards and in particular regarding BEPS Action 4 on the limitation of base erosion involving interest deductions and other financial payments. Hence, no changes to French law are expected in this area in the short term.

COUNTRY-BY-COUNTRY REPORTING, OTHER BEPS ACTIONS

However, the French government has indicated that it plans to introduce, in the Amended Finance Bill for 2015, French rules on country-by-country reporting, in accordance with the OECD recommendation.

The government also specified that France is working on the development of the multilateral‎ instrument to implement the tax treaty-related BEPS in order for this instrument to be adopted in 2016