France: Transfer pricing documentation measures | KPMG Global
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France: Transfer pricing documentation measures included in new law

France: Transfer pricing documentation measures

Newly enacted law in France includes updated transfer pricing documentation rules.


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The Finance Law for 2018 was adopted by the French Parliament and, following examination by the French Constitutional Court (Conseil Constitutionnel), was published in the French official gazette (Journal Officiel) in late December 2017. 

The Finance Law for 2018 includes provisions updating the required contents of transfer pricing documentation for companies that are members of “large economic groups.” The aim is for the French transfer pricing documentation rules to be in line with the standard under Action 13 of the OECD’s base erosion and profit shifting (BEPS) project.

The transfer pricing documentation must now also include other information not requested before or more precise information on certain topics, concerning items such as:

  • The supply chain for the main goods and services as well as a functional analysis of the role of the various entities of the group
  • Intangible assets and intragroup agreements regarding such assets
  • Information (not previously required) regarding the substantial financing operations of the group, including with unrelated entities


For more information, contact a tax professional with Fidal* in France or with KPMG in the United States:

Gilles Galinier-Warrain | +33 1 55 68 16 54 | 

Patrick Seroin | +1 (212) 954-2523 |

* Fidal is a French law firm that is independent from KPMG and its member firms.

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