Spontaneous application

Publication of Country by Country Reporting (CbCR)

Primexis Insights
14 November 2016
peopls talking

The European directive (UE) n°2016/881 of 25 May 2016, including the Country by Country Reporting (CbCR), has been transposed into French legislation by French decree, n° 2016-1288 of 29 September 2016 in application to article 223 quinquies C of the General Tax Code..


Objective: Means of implementing simple and proportionate responsibility to large multinationals in tax matters without harming their competitiveness.
To better understand the tax systems of EU member states and to help identify gaps and existing inconsistencies, by the control of transfer pricing.

For whom? Multinationals, French or not, companies that operate in France and whose global consolidated turnover is higher or equal to 750M euros per year.

When? It applies to fiscal years beginning 1 January 2016. Thus, the first declaration should be submitted no later than 31 December 2017 for companies who close their annual accounts according to civil calendar year.

How? The information (aggregated data) country by country will be included in a report prepared annually (maximum within 12 months after closing) and will be submitted electronically.
Note, confidential business information will not be published.


  • The turnover made from Intercompany transactions;
  • The turnover made from transactions with independent third parties;
  • The total turnover;
  • The profit or loss made before tax;
  • The amount of income tax paid;
  • The amount of income tax due;
  • The share capital;
  • The retained earnings at the end of the year;
  • The number of FTE employees (full time equivalent);
  • The tangible assets without cash and cash equivalent.


The nature of main activities of each entity is taken from the following list:

  • Research and Development;
  • Management of intellectual property right;
  • Purchases and supplies;
  • Fabrication or production;
  • Sales, marketing or distribution;

Sanctions: Default on subscriptions would be sanctioned by a fine of 100 000 EUR.

This European directive and its transposition by decree into the French law have an impact on companies established in France, whether they are French or international. Each of them will have to provide the information required in a report prepared annually by the parent company (leading company established in France or, in some cases, a French entity of an international group).

Primexis, an independent Consulting and Accounting Firm located in Paris, and is specialized in assisting groups and subsidiaries of French and international companies for more than 30 years, assists you in collecting and presenting this information in an annual report.

Stefan Petrovski
qualified Chartered Accountant
International Business Services

These posts may interest you