CbCR : French Tax Authorities releases the tax form

On 2 February 2017, the French tax authorities released the form 2258-SD that must be used for purposes of filing the country-by-country (CbC) report by groups falling within the scope of article 223 quinquies C of the French Tax Code:

  • French ultimate parent entity of a multinational group establishing consolidated accounts with annual consolidated turnover equal or exceeding 750 million Euros
  • French entities of a foreign group falling within the scope of article 223 quinquies C of the French Tax Code, if the CbC report has not already been filed with a tax authority that would share it automatically with the French tax authorities

Form 2258-SD is in line with the template provided by OECD’s final report on action 13 of the BEPS project and the EU directive regarding the mandatory automatic exchange of information in the field of taxation, with two specificities:

  • For entities listed in Table 2, the intra-EU VAT number together with the precise address must be disclosed
  • Additional Information and explanations included in Table 3 must be drafted in English language

Under France’s CbC reporting rules, multinational companies must file an annual CbC report within 12 months of the financial year-end for financial years commencing on or after 1 January 2016.

Grégoire de Vogüé

Grégoire de Vogüé, Partner, heads the Transfer Pricing team. He has acquired more than 20 years in all transfer pricing issues and corporate strategy. His multidisciplinary skills combined with his […]

Eric Lesprit

Eric has more than 25 years’ experience in transfer pricing and international tax. He held various senior positions at the French Tax Administration in relation to tax audit, tax policy […]

Aymeric Nouaille-Degorce

Aymeric Nouaille-Degorce, Partner, is a member of the Transfer Pricing’s team. He has more than 22 years of experience in this area, including more than six years spent within the […]

Julien Pellefigue

Julien Pellefigue, Partner, is an Economist in the Transfer Pricing department of Deloitte Société d’Avocats. He has more than 13 years of consulting experience both in economic consulting (transfer pricing […]