France: Country-by-country reporting added to Finance Bill, 2016

France: Country-by-country reporting

A new article requiring “country-by-country reporting” by the largest multinational enterprises was added to the Finance Bill for 2016. This country-by-country reporting requirement generally reflects the OECD base erosion and profit shifting (BEPS) recommendations, and was added by amendment to the Finance Bill for 2016.

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Pending rules in France

Parent companies of multinational groups with annual revenue exceeding €750 million would be required to file a country-by-country report within 12 months following the end of the fiscal year. Failure to file this report would be subject to a €100,000 penalty.

The tax administration in France would then transmit the country-by-country reports to other countries where the group has its operations, via an information exchange mechanism provided for by the subject tax treaties, under the condition of reciprocity.

The country-by-country reporting requirement also would extend and apply to French subsidiaries of multinational groups whose “head company” is established in a country or territory that does not in fact transmit country-by-country reports to France. However, in such instances, these multinational groups could still be required to file the report through one of their other entities located in a country that collects such information and from which the other treaty partners—including France—could receive it. 

KPMG observation

Tax professionals with Fidal* have observed that the format of the country-by-country report is expected to be based on the international standard, and would be defined by decree. The pending bill provides that the new country-by-country reporting obligation would apply to fiscal years beginning on or after 1 January 2016, with the first reports to be filed by the end of 2017.

 

For more information, contact a tax professional with Fidal* in Paris:

Olivier Ferrari | +33 (0)1 55 68 14 76 | olivier.ferrari@fidal.com   

Olivier Schmitt | +33 (0)1 55 68 15 92 | olivier.schmitt@fidal.com 

 

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

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