The Finance Bill for 2014 of France was published on December 30, 2013. The bill contains transfer pricing provisions but the Constitutional Court has rejected certain controversial provisions.

As approved by the Constitutional Court the Finance Bill for 2014 will include:

  • Tax deductibility limit on interest of related party loans.
  • During a tax audit compulsory delivery of “analytical accounts” and “consolidated accounts” to the French tax authorities
  • Cancellation of the provision of automatically collection of tax while filling a mutual agreement procedure case.