FRANCE: STATUS OF TRANSFER PRICING DOCUMENTATION, COUNTRY-BY-COUNTRY REPORTING

Legislative proposals being considered in France would require the automatic filing of transfer pricing documentation and, as part of this documentation, country-by-country reporting.

STATUS OF PROPOSALS

The Finance Committee of the French National Assembly has started its consideration of tax provisions relating to the second part of the Finance Bill for 2016. One provision (Amendment II-CF362) proposes the following transfer pricing changes:

• Transfer pricing documentation reports would have to be filed with the tax administration—and not just made available in a tax audit.
• Country-by-country (CBC) reporting would become a compulsory section of the documentation and would be based on the model provided in Actions 13 of the OECD’s base erosion and profit shifting (BEPS) plan. A taxpayer’s CBC report would not be subject to public disclosure. The list of required information would be limited to that requested from financial institutions
  pursuant to the CRD-IV Directive (i.e., the EU capital requirements directive, Directive 2013/36/EU).

As proposed, these measures would have an effective date of 1 January 2017.

For more information, contact a tax professional with the Global Transfer Pricing Services group (FIDAL*) in Paris:
Kate Noakes | + 33 1 55 68 16 57 | kate.noakes@fidal.com