France Transfer Pricing Policy

Email: par4ww@evershinecpa.com
Manager Zhu, speak in French English and Chinese

TP-Q-10
Why kinds of scenarios will be adopted TP policy? What is the relevance between DTA and TP policy?

TP-A-10
When a France Tax entity would like to pay out whatever business profits, Royalty, Technical Services fees, Interests, trading amount, etc., it will adopt DTA tax rate. Its judge criteria, please see the France Treaty Page.
But if want to verify the above-mentioned amount if reasonable, will adopt France TP Policy.

TP-Q-20:
在法國甚麼情況下, WFOE 外商投資企業不需要同時處理TP 申報和文件申報?
What are the scenarios in France, that a Wholly Foreign-Owned Entity (WFOE) is exempted from compliance of Transfer Pricing (TP) declaration and TP documentation?

TP-A-20:
WFOE is exempted from preparing TP declaration and TP documentation if the Gross annual turnover or gross assets < Euro 50 million.

TP-Q-30:
在法國甚麼情況下, WFOE 外商投資企業需要向該國的稅務局發送TP 申報? 甚麼是申報單名稱?
What are the scenarios in France, that a Wholly Foreign-Owned Entity (WFOE) is required to submit TP declaration to the country’s tax bureau? What is the name of the TP declaration form?

TP-A-30:
Form 2257-SD (TP Declaration form) – Gross annual turnover or gross assets >= Euro 50 million.

TP-Q-40:
在法國甚麼情況下, WFOE 外商投資企業需要向該國稅務局發送TP 申請和文件? 甚麼 declaration 表單名和文檔名?
What are the scenarios in France, that a Wholly Foreign-Owned Entity (WFOE) is required to submit TP declaration and TP documentation to the country’s tax bureau?
What is the name of the TP declaration form and TP documentation form?

TP-A-40:

1. France taxpayers exceeding any of the following thresholds are required to prepare Form 2257-SD (TP Declaration):
   1.1 Gross annual turnover or gross assets >= Euro 50 million.
   1.2 Hold or are held by, directly or indirectly, a legal entity that satisfied Euro 50 million threshold above.

2. France taxpayers exceeding any of the following thresholds are required to prepare Local and Master File:
   2.1 a company having a turnover or gross assets equal to or exceeding Euro 400 million;
   2.2 a company owned by or owning directly or indirectly more than 50% of a company with a turnover or gross assets equal to or exceeding Euro 400 million; and
   2.3 a company that is a member of a tax consolidated group, where at least one company meets one of the above requirements.

3. France taxpayers exceeding the following threshold are required to prepare Form 2258-SD (CbC Report):
   3.1 An ultimate Parent Entity having Consolidated revenue > Euro 750 million.

France TRANSFER PRICING for professionals

Overview
France adheres to the OECD’s guidelines on transfer pricing.
Transfer pricing rules in France apply to cross-border transactions between France and a foreign-related entity.
France transfer pricing rules also allow the tax authorities to adjust tax computations in the case of non-arm’s-length commercial transactions.
Under article L 13 AA of the French tax procedure code (FTPC), legal entities established in France, having intra-group transactions with foreign related parties are subject to the TP documentation requirement.

Related Party

Associated enterprises are foreign entities where:

1. One enterprise directly or indirectly owns the majority of the share capital of the other or effectively exercises decision-making powers within the other enterprise.
2. Both enterprises are under the control of the same third enterprise (control as above).

Transfer Pricing method
France legislation does not make any specific references to which are acceptable transfer pricing methodologies.
Below is the acceptable TP method.

1. Comparable Uncontrolled Price (CUP)
2. Resale price method (RPM)
3. Cost-plus method (CPM)
4. Profit split
5. Transactional net margin method

Due dates and respective threshold:

Please be aware of below Warning:
The above contents are digested by Evershine R&D  and Education Center in October 2021.
Regulations might be changed as time goes forward and different scenarios will adopt different options.
Before choosing options, please contact us or consult with your trusted professionals in this area.

Contact Us

Paris Evershine BPO Service Limited Corp.
Email: par4ww@evershinecpa.com
Manager Zhu, speak English and Chinese

or
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