10 January 2018

France aligns transfer pricing documentation requirements with OECD Action 13 Master File and Local File

The French Finance Bill for 2018, approved by the Parliament on December 21, 2017 and published in the Journal Officiel on December 31, 2017, aligns French transfer pricing documentation requirements with the Organisation for Economic Co-operation and Development (OECD) Base Erosion and Profit Shifting (BEPS) Action 13 recommendations (Transfer Pricing Documentation and Country-by-Country Reporting) by amending Article 13 AA of the French tax procedures code. Specifically, the OECD's BEPS Action 13 recommends that multinational enterprise (MNE) groups should disclose additional information in their transfer pricing reports and proposed a standardized format for the disclosure of general information on the group (Master File) and more detailed information for each taxable entity that is part of the group (Local File).

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

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ATTACHMENT

Full text of Tax Alert 2018-0049

Document ID: 2018-0049