Strategizing International Tax Best Practices – by Keith Brockman

Posts tagged ‘France transfer pricing’

France: CbC public reporting receives a last-minute “no” vote

Following up the post of 8 December, France’s National Assembly provided a last-minute “no” vote with respect to providing country-by-country (CbC) reports for the public domain.

This has incited an outcry by the enthusiasts behind the transparency measure for additional insight into a multinational’s global tax posture.

Notwithstanding the “no” vote in France, this scenario is expected to emerge in other countries as the OECD BEPS implementation of CbC reporting is established in the local legislative frameworks.

In summary, the premise of multinational organizations for public CbC reports should still be the framework behind the date gathering process that is commencing.

France TP Disclosure form

The transfer pricing information return tax form has been released to provide 2013 information.  The form is to be completed in French with a due date of 20 November 2014.  A reference to the form is attached:

http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Pages/2014-1/france-final-version-information-return-transfer-pricing.aspx

Best Practice observation: As more countries initiate transfer pricing disclosure forms, including the types of transfer pricing methodologies being used, it is imperative to align these disclosures with the annual transfer pricing documentation.  Accordingly, there should be clear communication with the Business re: advice to properly file such disclosures.

Transfer pricing disclosures: France & Serbia

Annual transfer pricing disclosures are increasing around the world.  Summaries of recent legislation requiring annual transfer pricing information for France and Serbia, summarized by KPMG, are provided for reference.  The annual transfer pricing disclosures for France reflect a summary of information from the transfer pricing documentation report to be provided upon request in an audit, whereas Serbia’s transfer pricing “Rule Book” forms a link to the OECD Guidelines.

http://www.kpmg.com/Global/en/IssuesAndInsights/ArticlesPublications/taxnewsflash/Pages/france-abridged-transfer-pricing-documentation-to-be-filed-annually.aspx

Click to access tp-serbia-jul-22-2013.pdf

Best Practices include a methodology to capture such disclosures contemporaneously to provide time for planning and execution.  Additionally, the country Business Unit, relevant tax team members and advisors should be aligned with such legislation in advance of the respective due dates.

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