On 12 December 2013 it was reported that recently enacted transfer pricing legislation includes a new requirement for large taxpayers to file annually an “abridged” version of their transfer pricing documentation.
The requirement to file the abridged transfer pricing documentation annually applies to “large” legal entities established in France and subject to the French documentation requirements under Article L13AA of the French tax procedure code—that is, entities that satisfy one of the following requirements:
• Having an annual turnover or gross assets of €400 million or more;
• Being directly or indirectly owned for more of 50% of their share capital/voting rights by a legal entity (French or foreign) meeting the €400 million turnover or gross assets threshold;
• Directly or indirectly owning more than 50% of the share capital or voting rights in a legal entity (French or foreign) meeting the €400 million turnover or gross assets threshold; or
• Belonging to a French consolidated group including a company falling within the scope of Article L13AA.
Annual submission deadline
These documents and information must be submitted to the French tax administration within six months of the date of the tax return filing (in practice this is within nine months of the end of the fiscal year or 10 months for enterprises with fiscal years ending on 31 December).
In practice, for the financial year ending 31 December 2013, the reporting requirement must be satisfied within the six months following the tax return filing deadline (5 May 2014)—or before 5 November 2014.
