France: Decree implementing country-by-country reporting

France: Decree implementing CbC reporting

A decree relating to the application of country-by-country (CbC) reporting has been approved by the French government. The decree (Decree N°2016-1288 of 29 September 2016) provides insight into the practical application of CbC reporting and introduces into French regulations certain provisions included in the OECD’s base erosion and profit shifting (BEPS) Action 13.

Related content

The decree provides for the following guidance.


  • Qualifying entities within the scope of the CbC reporting rules are those subject to a legal obligation to prepare consolidated accounts. 
  • A company or branch falling outside the consolidation requirements also must be included as part of the CbC reporting. 
  • Details of data to be reported is set forth.
  • All entities located in a particular territory must be listed in the CbC report. Entities incorporated in a territory different to that of their establishment must be mentioned in both territories. 
  • The financial data to be declared on the CbC reporting form must be extracted from the consolidated financial statements, from each company’s statutory accounts, or from management accounts. This choice of information must be consistent for all entities listed on the CbC reporting form. 
  • The data to be declared must be that of the financial year of the group’s ultimate parent company. The data to be reported for subsidiaries and branches with different year-ends must be the data from their most recent financial year, ended before the group ultimate parent company’s year-end. 
  • French entities subject to the CbC reporting requirement must note that they have this obligation in their annual corporate income tax return as well as must indicate whether they will be making the CbC report filing. 
  • When another entity has been selected to file the CbC report, the name and location of this entity must be indicated on the French company’s corporate income tax return. 
  • The CbyC reporting form can be filed electronically.


For more information, contact a tax professional with a Fidal* associated with KPMG’s Global Transfer Pricing Services group:

Kate Noakes |

Olivier Kiet |

Nadia Sabin |

Gilles Vincent du Laurier |

Anne-Laure Goetzinger |


* Fidal is a French law firm that is independent from KPMG and its member firms.

© 2016 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Request for proposal



KPMG's new digital platform

KPMG's new digital platform