On 5 December 207, the French tax authorities released a new rule regarding the country-by-country (CbC) reporting obligations provided for by article 223 quinquies C of the French General Tax Code. According to OECD guideline jurisdictions should require the timely filing of CbC reports by the ultimate parent entities of multinational enterprise (MNE) groups resident in their countries and exchange this information, on an automatic basis, with the jurisdictions in which the MNE group operates and in which subsidiaries meet the requirements for filing the CbC report. According to the OECD guideline when a jurisdiction does not exchange CbC reports or does not implement the requirement for fiscal years beginning on or after 1 January 2016, but has its legislation in place the Company or MNE group can submit the CbC report using two process. Either through Surrogate parent filing where a constituent entity in a different jurisdiction that allows filing of CbC reports by surrogate parent entities, files the CbC report voluntarily; or through Ultimate parent surrogate filing where voluntary filing for ultimate parent entities resident in their jurisdiction. If either of the above filling process are there, no other local filing obligation is needed for the subsidiaries of the MNE group in any jurisdiction that has an agreement with the ultimate parent entity jurisdiction of residence.
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