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The French Finance Bill for 2016 has also implemented the country-by-country filing requirement in France in view to comply with Action 13 of the OECD BEPS Project.

The measure will apply for the first time to financial year beginning the 1st of January 2016. The report will have to be filed with the French tax authorities within twelve months following the end of the financial year, i.e., for the first time in 2017 (for entities closing their accounts on 31 December 2016).

Which entities are concerned?

Any entity established in France which belongs to a multinational group releasing consolidated accounts and whose group realizes annual consolidated turnover, excluding VAT and indirect taxes, of at least EUR 750 million.

According to the Finance Bill, the report should include the description of the activity carried out by the group in each country and the breakdown of the profits as well as other economic, accounting and tax indicators. The detailed content of the report will be set by an administrative decree.

Any French subsidiaries of foreign groups whose ultimate parent entity is established in a State not requiring the country-by-country reporting.

Sanctions: A penalty up to EUR 100,000 shall have to be paid by entities failing to produce the report on time.

 

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