France: Transfer pricing documentation requirements | KPMG Global
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France: Transfer pricing documentation requirements, clarified and detailed

France: Transfer pricing documentation requirements

A decree—n°2018-554 (29 June 2018)—clarifies the requirements for the content of and the format for presenting transfer pricing documentation under French tax law (article L. 13 AA of the tax procedure law).


Related content

In general, the transfer pricing documentation requirements provide:

  • Transfer pricing documentation must be available for the local tax administration in an electronic format that allows for the exchange and reading of the documents. 
  • A standardized format for the disclosure of general information of the taxpayer group (Master file or also referred to as the Principal file) and more detailed information for each taxable entity that is part of the group (Local file). 

Specific requirements for Master, Local files

Taxpayer companies will need to verify that their transfer pricing documentation reports comply with the following requirements:

  • Data tables must follow a pre-defined format and be presented in an electronic format that allows the tax administration to validate the taxpayer’s calculations.
  • The Master (or Principal) file format must collect information and present it in five sections (in the following order):
    • Organizational structure (corresponding to “point a” under section 1 of II of the statute (article L. 13 AA))
    • Description of the multinational group’s field or fields (corresponding to “points b to g” of section 1 from II of the statute)
    • Multinational group’s intangible assets (corresponding to “points h to k” of section 1 from II of the statute)
    • Multinational group’s intercompany financial assets (corresponding to “points l to n” of section 1 from II of the statute) 
    • Fiscal and financial situation of the multinational group (corresponding to “points o and p” of section 1 from II of the statute)
  • The Local file must be presented in three sections and in the following order:
    • The entity in France (corresponding to “points a and b” of section 2 from II of the statute (article L. 13 AA))
    • Controlled transactions (corresponding to “points c to p” of section 2 from II of the statute)
    • Financial information (corresponding to “points q to s” of section 2 from II of the statute)


For more information, contact a transfer pricing professional with Fidal* 

Nadia Sabin | +33 (0) 1 55 68 17 38 |

Elfie Ossard-Quintaine | +33 (0) 1 55 68 14 78 |

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

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