France: Status of transfer pricing documentation, country-by-country reporting

Country-by-country reporting in France

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.

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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 Action 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

 

* FIDAL is an independent legal entity that is separate from KPMG International and its member firms.

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.

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