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.
«
Italy: CbC reporting requirements
Azerbaijan: VAT on Uber rides
»
Related Posts
France publishes updated list of participating and reportable jurisdictions for CRS purposes
On 28 March 2024, France's Official Journal No. 0074 published the Order of 15 March 2024, which provides a comprehensive and current list of participating and reportable jurisdictions for Common Reporting Standard (CRS) purposes. Common Reporting
Read MoreFrance: Tax authorities publish individual income tax return deadlines for 2024
The French tax authorities released the schedule for submitting the individual tax returns for 2024 in respect of the 2023 tax year. The online tax filing service became accessible through impots.gouv.fr starting 11 April 2024, with filing deadlines
Read MoreFrance publishes 2024 Q1 floating rate for shareholder loans
On 28 March 2024, the Official Journal of France released the inaugural quarterly average floating rate for bank loans and credit facilities exceeding two years in maturity for 2024. This rate is utilized in determining the yearly maximum interest
Read MoreFrance updates non-cooperative states and territories list
The French General Tax Code's list of non-cooperative States and territories (NCSTs) was updated via Decree on 16 February 2024 and published in the Official Journal on 17 February 2024. The list includes the following 16 states and territories:
Read MoreFrance extends DAC7 reporting deadline
The execution of EU Directive 2021/514 (DAC7), which mandates the automatic exchange of income information from digital platforms, is facing hurdles and technical issues in various member states. DAC7 establishes 31 January 2024 as the deadline for
Read MoreFrance enacts 2024 finance law with global minimum tax rules
On 30 December 2023, France released its Finance Law for 2024 (Law no. 2023-1322) in the Official Gazette, along with the Constitutional Court's review, affirming the constitutionality of key tax measures. A major highlight is the implementation of
Read More