Ministerial Order of 24 April 2026 revises jurisdictions eligible for exemption from local filing under CbC rules. New jurisdictions added reflect updated exchange agreements and compliance with reporting requirements.
France has published a Ministerial Order on 24 April 2026, published in Official Journal No. 0099 of 26 April 2026, updating the list of jurisdictions that meet the conditions for exemption from local filing under its country-by-country (CbC) reporting framework.
The update amends the existing rules set out in the Decree of 6 July 2017 and reflects jurisdictions that have implemented CbC reporting requirements, concluded agreements with France for the automatic exchange of CbC reports, and comply with those agreements.
Under Article 223 quinquies C of the French General Tax Code (CGI), multinational enterprise groups with an annual consolidated turnover of EUR 750 million or more are required to file a country-by-country declaration. However, French constituent entities may be exempt from local filing where the ultimate parent entity is resident in a jurisdiction that satisfies the relevant reporting and exchange conditions.
For fiscal years beginning on or after 1 January 2023, the updated list adds the Dominican Republic, Mongolia, Senegal, Serbia and Vietnam.
For fiscal years beginning on or after 1 January 2024, the revised list includes Albania, Antigua and Barbuda, Cameroon, the Faroe Islands, Liberia, Montenegro, Montserrat and Ukraine, alongside EU Member States and other qualifying jurisdictions.
The order entered into force on the day following its publication.
