Wednesday, 29 March 2017

France's tax authorities approves CbC form

On 2 February 2017, the French tax authorities released the form that must be used by groups of companies that are required to file the country-by-country (CbC) report. CbC reporting (in line with the OECD’s recommendations under
action 13 of the BEPS project) was adopted in the 2016 Finance Law and included in the tax code as article 223 quinquies C.
The following entities are required to file the form:

  • A French ultimate parent entity of a multinational group whose consolidated revenue is EUR 750 million or more; and
  • French entities of a foreign group that falls within the scope of article 223 quinquies C, if the CbC report has not already been filed with a tax authority that would automatically share the report with the French tax authorities.

The form (Form 2258-SD) is in line with the template provided by the OECD in the final report on BEPS action 13, as well as the EU directive on the mandatory automatic exchange of information in the field of taxation. However, the French form also requires that the intra-EU VAT number and the exact address be disclosed, and certain information and explanations must be included in English.
Under France’s CbC reporting rules, multinational companies must file an annual CbC report within 12 months of the financial year-end for financial years commencing on or after 1 January 2016.

Source: Deloitte