France: Decree implementing CbC reporting | KPMG | GLOBAL
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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.


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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.

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