Press Room

January 19, 2017

From France: Transfer Pricing Obligations Changes


Denis Fontaine-Besset - STC Partners, a Member Firm of Andersen Global

In France, a new law has come into effect, increasing the range of companies held liable for certain transfer pricing obligations. Previously, only French taxable entities (including French controlling entities and controlled entities or members of same French tax group as entities) with revenues or assets exceeding 400 Million Euros were subject to specific transfer pricing obligations, including:

Preparation of a detailed documentation to be provided to the tax administration upon request during tax audits.
Preparation of a spontaneous simplified declaration due within six months after the due date for the filing of the annual tax return.

The threshold for the latter obligation has been reduced down to 50 Million Euros. The reduced threshold is effective for tax years ending on December 31, 2016 or later. The due date for such obligations can be as early as November 3, 2017. 

For further information on changes to Transfer Pricing Changes and a potential extension, please contact Denis Fontaine-Besset.