This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French government on 14 February 2022 issued a decree updating the
This article was first published on Tax@Hand, and is reproduced on this blog with the authorization of its authors. The French government on 14 February 2022 issued a decree updating the
Under OECD recommendations, jurisdictions should require, in a timely manner, the filing of Country-by-Country declarations by the ultimate parent companies of MNE group resident in their countries and exchange this
Following on from the BEPS and in particular Action 13 reports, the OECD has recently published three important documents aiming at providing greater legal certainty for tax administrations and multinational
Two major changes in filing obligations are to be noted: The threshold above which a taxpayer should file the transfer pricing return(formulaire 2257 SD, Article 223 quinquies B du CGI)
This article was first published in Les Cahiers de l’IFA, volume 102, The future of transfer pricing, July 2017 Download the original version of this article This article
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
In the context of the implementation of the Country by Country reporting, the OCDE offered the option for countries to introduce provisions requiring a notification from the local constituent entities