France

Overview of CbC reporting requirements

France has implemented the BEPS Action 13 (CbC reporting) minimum standard with two recommendations for improvement.

First reporting fiscal year: Commencing on or after 1 January 2016

Consolidated group revenue threshold: EUR 750 million

Filing deadline: 12 months following the end of the reporting fiscal year

Local filing required: Yes

Surrogate parent entity filing permitted: Yes

First review of the domestic legal framework: 2017/2018

Summary of recommendations

Area of implementation	Recommendations for improvement
Domestic legal and administrative framework	It is recommended that France introduce a provision which would have an equivalent effect as the “deemed listing provision”, i.e. ensuring that all entities that are not legally required to prepare Consolidated Financial Statements (whether under commercial / company law, or under regulations governing the relevant stock exchange / market, or other) be included in the scope of the parent entity filing obligation. It is recommended that France ensure that local filing only occurs in the circumstances contained in the terms of reference.
Exchange of information framework	None.
Appropriate use	None.

The domestic legal and administrative framework

It is recommended that France introduce a provision which would have an equivalent effect as the “deemed listing provision”, i.e. ensuring that all entities that are not legally required to prepare Consolidated Financial Statements (whether under commercial / company law, or under regulations governing the relevant stock exchange / market, or other) be included in the scope of the parent entity filing obligation. This recommendation remains in place since the 2017/2018 peer review.

It is recommended that France ensure that local filing only occurs in the circumstances contained in the terms of reference. This recommendation remains in place since the 2017/2018 peer review.1 2

The exchange of information framework

France confirms that its rules have not changed and continue to be applied effectively. France continues to meet all terms of reference.

Appropriate use of CbC reports

France confirms that its rules have not changed and continue to be applied effectively. France continues to meet all terms of reference.

Notes

← 1. France’s 2017/2018 peer review included three monitoring points on the parent entity filing obligation. These monitoring points remain in place.

← 2. France’s 2017/2018 peer review included a monitoring point with respect to the limitation of local filing to the instances of “Systemic Failure” as defined in paragraph 21 of the terms of reference. France confirms that its legislation implies that the obligations under the CbC MCAA are complied with (in particular the obligation for a prior consultation between Competent Authorities under Section 6 of the CbC MCAA) and will only apply local filing if there is a “Systemic Failure”. This monitoring point remains in place.