A list of jurisdictions that have introduced Country-by-Country reporting requirements and have concluded a competent authority agreement on the automatic exchange of CbC reports with France was published in the French Official Journal on 8 July 2017.
For tax years commencing on or after 1 January 2016, all EU Member States and Australia, Bermuda, Brazil, Canada, Chile, China, Guernsey, Indonesia, Jersey, Mexico, New Zealand, Norway, South Africa and South Korea are included in the list. For tax years commencing on or after 1 April 2016, the list also includes India and Japan.
French constituent entities of foreign MNE groups whose UPE is tax resident in a country with which France has concluded a competent authority agreement on the automatic exchange of CbC reports are not subject to local filing in France. Otherwise, any French constituent entity of a foreign MNE group whose UPE is not tax resident in a country included in the list may be required to file a CbC report in France.
