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France: Reduced threshold, eligibility for abridged transfer pricing documentation

France: Abridged transfer pricing documentation

New law in France, enacted 8 November 2016, provides for a reduced threshold for taxpayers to be eligible for filing the “abridged” transfer pricing documentation (Form 2257).


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The threshold—as codified at Article 223 quinquies B of the French general tax code—is reduced from €400 million to €50 million of turnover or gross assets, effective for accounting periods closing on or after 31 December 2016. 

The reduced threshold applies not only at the level of the French entity (subsidiary or branch), but also at the level of any other company within the taxpayer group. Therefore, if there is one company (e.g., the French company or one of its parent, sister or subsidiary companies) that has a turnover or gross assets of more than €50 million, then the related French entity will be required to file with the French tax authorities Form 2257 that includes specific transfer pricing information. This form will need to be filed electronically ever year, and by the latest, six months after the tax return. 

Three levels of documentation

In France, there are three levels of transfer pricing documentation requirements for 2016:

  • Country-by-country reporting—codified in the French tax code in December 2015 as Article 223 quinquies C. Entities subject to this requirement are companies that create and maintain consolidated accounts, belong to a group with a consolidated turnover in excess of €750 million and have foreign branches or hold or control, directly or indirectly, foreign entities. A recent decree (n°2016-1288) approved by the French government, provides information regarding information to be disclosed.
  • Transfer pricing documentation—codified in Article L 13 AA of the French tax procedures law. Entities established in France that meet a turnover or gross assets threshold of €400 million (or that own, or are owned by, directly and indirectly, more than a half of a corporate entity’s capital or voting shares that exceeds that threshold), are to make the documentation available to the French tax authorities at the outset of a tax audit.
  • Abridged transfer pricing documentation—Form 2257 includes both general information on the group of associated enterprises (general description of the activities, list of main intangibles assets owned, and general description of the group’s transfer pricing policy) and specific information on the French taxpayer (description of the activity, presentation of intragroup transactions including the nature and the amount when the aggregate amount per transaction type exceeds €100,000, and a presentation of the transfer pricing method(s).


For more information, contact a tax professional with Fidal* and the 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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