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France: Annual transfer pricing return, filing deadline postponed (COVID-19)

France: Annual transfer pricing return, filing deadline

The French tax administration indicated that because the deadline for filing the corporate income tax return for 2019 has been extended as a relief measure in response to the coronavirus (COVID-19) pandemic, the deadline for filing the annual transfer pricing return is also being extended.

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The annual transfer pricing return (Form 2257-SD) is due six months after the filing deadline for the corporate income tax return. Given the extended deadline for filing the corporate income tax return, Form 2257-SD is now to be filed no later than:

  • 31 December 2020 (for companies with financial year ended on 31 December 2019, 31 January 2020 and 29 February 2020)
  • 31 January 2021 (for companies with financial year ended 31 March 2020)


Transfer pricing: Documentation and reporting requirements

Under French law, there are three main types of transfer pricing documentation and reporting requirements:

  • Country-by-country (CbC) reporting (Article 223 quinquies C of French general tax law)
  • Master file and Local file documentation requirement (Article L.13 AA and Article L. 13 AB of French tax procedures book)
  • Annual transfer pricing declaration on Form 2257-SD (Article 223 quinquies B of the French general tax law)—this is also known as the “abridged transfer pricing documentation”


Annual transfer pricing declaration (Form 2257-SD)

Companies with gross annual turnover or gross assets equal to or exceeding €50 million, or that hold or are held by, directly or indirectly, a legal entity that satisfies the €50 million threshold must file with the French tax authorities, a document that is to contain part of the elements typically included in a transfer pricing documentation report. This filing requirement applies for a six-year period.

Form 2257-SD requires the company to report certain general information about the French company and its corporate group, and to report information about aggregate amounts of cross-border transactions exceeding €100,000 (per type of transaction).

Form 2257-SD is filed electronically, each year, by a date that is within six months following the filing of the annual income tax return.


Postponed filing date for annual transfer pricing return

Because of the COVID-19 crisis, the deadline for filing the 2019 corporate income tax return was extended:

  • To 30 June 2020 for companies with financial year ended on 31 December 2019, 31 January 2020, and 29 February 2020
  • To 31 July 2020 for companies with financial year ended 31 March 2020

The French tax administration in recent “frequently asked questions” (posted on the website of the Public Finances Directorate) stated that the extended filing deadline for 2019 corporate income tax returns also postponed the filing deadline of the annual transfer pricing return (Form 2257-SD) to six months after the extended corporate income tax return filing deadline.

Accordingly (as noted above), Form 2257-SD is due to be filed no later than:

  • 31 December 2020 (for companies with financial year ended on 31 December 2019, 31 January 2020, and 29 February 2020)
  • 31 January 2021 (for companies with financial year ended 31 March 2020)

There is currently no information about a potential extension of the deadline for the other transfer pricing reporting requirements, including the CbC report.


For more information, contact a tax professional with KPMG Avocats in France:

Marie-Pierre Hôo | + 33 (0) 1 55 68 49 09 | mhoo@kpmgavocats.fr

Elfie Ossard-Quintaine | + 33 (0) 1 55 68 49 52 | eossardquintaine@kpmgavocats.fr

Christel Perez-Cuccureddu | + 33 (0) 1 55 68 49 89 | cperez-cuccureddu@kpmgavocats.fr

Olivier Kiet | + 33 (0) 1 55 68 49 54 | okiet@kpmgavocats.fr

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