In France, a new law had been enacted on 8 November 2016 which provides for a reduced threshold for taxpayers to be eligible for filing the “abridged” transfer pricing documentation (Form 2257).
The threshold as codified at Article 223 quinquies B of the French general tax code is reduced from €400 million to €50 million of turnover or gross assets, effective for accounting periods closing on or after 31 December 2016 as per the New law in France.
This reduced threshold will be applicable not only at the level of the French entity (subsidiary or branch), but also at the level of any other company within the taxpayer group.
Thus, if a French company or one of its parent, sister or subsidiary companies has a turnover or gross assets of more than €50 million, then the related French entity will be required to file with the French tax authorities Form 2257 that includes specific transfer pricing information. The Form will have to be filed electronically ever year, and by the latest, six months after the tax return.
