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12 December 2017

French Country-by-Country Reporting requirements may affect US multinational groups

The French Government published additional comments on December 4, regarding the potential treatment of Country-by-Country (CbC) Reporting (CbCR) requirements of French subsidiaries and branches of foreign multinationals, where the country of residence of the foreign multinational has not yet signed the automatic exchange of information agreement with France. This is, for example, the case for US-based multinational enterprises that have to comply with CbCR requirements in France. Although the French Government, in this most recent publication, aims to provide increased comfort that no CbCR-related penalties would apply if certain conditions are met, its December 4 announcement still leaves room for interpretation and fails to provide the legal certainty sought after by French entities and their parent companies.

A Global Tax Alert, attached below, provides additional details.

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ATTACHMENT

Full text of Tax Alert 2017-2101

Document ID: 2017-2101

 

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