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.