The French legislator, under the impetus of international organizations, has strengthened the requirements regarding transfer pricing documentation. New rules include regular audits on French and foreign taxpayers of both their practices and the preparation of documentation in accordance with the regulations in force.

Obligations concern more notably:

Large Groups:

  • As the taxpayer, such Groups must provide full documentation in accordance with the requirements of Article L 13 AA of the LPF,
  • Country-by-country reporting – CbCR, Article 223 quinquies C of the CGI, form 2258 – SD: the annual declaration of certain financial and transactional aggregates on a global scale, to be prepared by a dedicated multidisciplinary team combining our specific skills in reporting and consolidation, IT and taxation.
  • Annual and simplified transfer pricing declaration in France, form 2257 – SD (Article 223 quinquies B of the CGI).

Medium-sized Groups:

  • Documentation in accordance with the OECD and EU recommendations and meeting the requirements of the French tax authorities (Article L 13 B of the LPF).
  • The annual simplified transfer pricing declaration in France, form 2257 - SD (Article 223 quinquies B of the CGI).