France: Tax authority publishes transfer pricing guidelines related to BEPS compliance
On 18 July 2018, the French tax authorities published instructions regarding Master / Local file in the context of transfer pricing documentation. As per the guidelines, the new documentation requirements apply for fiscal years beginning on or
See MoreFrance ratifies MLI to implement tax treaty related measures to prevent BEPS
On 12 July 2018, France ratified the bill by way of Law No. 2018-604, as published in Official Journal No. 0160 of 13 July 2018. On 5 July 2018, the National Assembly passed the bill for the ratification of the multilateral convention to implement
See MoreFrance publishes arm’s length interest rate for third quarter of fiscal year 2018
The arm’s length interest rates used in determining the deductibility of interest payments to shareholders for companies whose fiscal year ends between 30 June 2018 and 29 September 2018 has been published by France. The portion of interest
See MoreFrance: Senate approves Multilateral Instrument (MLI)
On 19 April 2018, the Senate approved the multilateral convention to implement tax treaty related measures to prevent BEPS (MLI). The agreement will enable France to implement international tax cooperation initiatives, including the automatic
See MoreLuxembourg and France sign new tax treaty
On 20 March 2018, Luxembourg and France signed a new income tax treaty and a new protocol, replacing the current double tax treaty signed on 1 April 1958. The Treaty contains a number of treaty-based recommendations including BEPS action 14 (making
See MoreFrance: Publishes new corporate taxation measures
The Ministry of the Economy and Finances published a summary of the main measures introduced by the Finance Law 2018 and the Social Security Finance Law 2018 regarding corporate taxation on 19 February 2018. These measures generally apply from 1
See MoreFrance: Requirement for Transfer Pricing Documentations being brought in
After disappearing from the draft, the Finance Bill 2018 undergoes revision of the last year’s requirements for transfer pricing documentation and brings in some additional changes to the requirements: Failure within the ambit of the
See MoreFrance: Change in Transfer Pricing Documentation Requirements
French Parliament updated their transfer pricing documentation rules. Under the Finance Act for 2018, which was approved by the Parliament on 21 December 2017, French companies must submit the transfer pricing documentation for financial years
See MoreUS: Government signs joint statement on exchange of country-by-country tax reports with France
On January 12, the IRS announced on its website that the US and French competent authorities would like to sign a joint statement to spontaneously exchange CbC reports submitted by their respective taxpayers. The Competent Authorities desire to
See MoreFrance: US Multinational Groups and the French Country-by-Country reports
The United States hasn’t been yet included in the French Ministerial Order consisting of the list of states for CbCR purposes. Discussions on the authority agreement between France and USA are still going on, which has a bit of suspense running
See MoreFrance : Temporary Exceptional Surcharge on Large Companies
The French Constitutional Court finalized the “exceptional surcharges” to levy on corporate income of the French largest companies. This exceptional surcharges apply to French companies or branches that are subject to corporate tax, and have
See MoreFrance: Country-by-country reporting
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
See MoreFrance: Parliament approves the first Amending Finance Bill for 2017
The French Parliament has approved the first Amending Finance Bill for 2017 that was validated by the French constitutional court. The administrative guidelines on temporary surcharge of large companies were released on 8 December 2017. This Bill
See MoreFrance: Constitutional Court confirmed its judgment on temporary surcharge on large companies
The French Constitutional Court declared its judgment on the recently approved temporary surcharge on large companies on the 29 November 2017. More than sixty Senators and more than sixty MPs criticized the procedure for passing the law. The
See MoreFrance: Government publishes draft second Amendment Financing Act for 2017
On 15 November 2017, a second draft amending Finance Bill for 2017 was submitted to the French Council of Ministers and was submitted to the French Parliament. The draft law emphasized the following tax measures for the coming year. Anti-Evasion
See MoreFrance: “exceptional surcharges” proposed for corporate tax of large companies
On 2 November 2017, the French government announced details of proposed “exceptional surcharges” which will be 15% and will be imposed on corporate income tax due by companies with gross revenue exceeding EUR 1 billion for financial years ending
See MorePakistan approves updating tax treaties with Sri Lanka, Nepal, France, Tunisia, Morocco, and Portugal
On 10 October 2017, the federal cabinet has granted approval to amend existing conventions on avoidance of double taxation treaties with Sri Lanka, Nepal, France, Portugal, Tunisia and Morocco for avoiding double taxation and the prevention of
See MoreFrance: Draft finance bill for 2018 released
The government of France released the draft Finance Bill for 2018 on 27 September 2017. The main changes outlined in the draft Bill are as follows: Decrease of the French corporate income tax rate Elimination of the 3% tax on dividend
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