New law in France, enacted 8 November 2016, 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.
The reduced threshold applies 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. Therefore, if there is one company (e.g., the French company or one of its parent, sister or subsidiary companies) that 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. This form will need to be filed electronically ever year, and by the latest, six months after the tax return.
In France, there are three levels of transfer pricing documentation requirements for 2016:
For more information, contact a tax professional with Fidal* and the Global Transfer Pricing Services group:
Kate Noakes | Kate.Noakes@fidal.com
Olivier Kiet | Olivier.Kiet@fidal.com
Nadia Sabin | Nadia.Sabin@fidal.com
Gilles Vincent du Laurier | Gilles.Vincentdulaurier@fidal.com
Anne-Laure Goetzinger | Anne-laure.Goetzinger@fidal.com
* Fidal is a French law firm that is independent from KPMG and its member firms.
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