France Transfer Pricing Documentation Requirements
France operates a contemporaneous documentation obligation that is produced on request rather than filed, but layers on top of it a separate annual Transfer Pricing Statement that larger entities must submit with the tax return. The two obligations run in parallel and carry distinct deadlines.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Entities caught by article L 13 AA (broadly, annual turnover or gross assets ≥ EUR 400m, or membership of such a group) | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN / FR | Yes (up to higher of 5% of reassessed profits or 0.5% of intra-group transactions) |
Local File Required | Same thresholds as the Master File | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN / FR | Yes (up to higher of 5% of reassessed profits or 0.5% of intra-group transactions) |
Transfer Pricing Statement Form 2257-SD
Annual filing | Entities within the article L 13 AA scope | Within 6 months of the tax return deadline | Submission deadline The documentation must be filed with the tax authority by the date shown. | FR | Yes (fixed penalty for non-filing or late filing) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
The full Master File and Local File obligation applies to entities caught by article L 13 AA of the Tax Procedure Code. In broad terms this captures companies with annual turnover or gross assets of at least EUR 400 million, together with French entities that belong to a group meeting that test. Both documents must be prepared on a contemporaneous basis and held available for the tax authority from the first request during an audit, at which point they must be produced within 30 days.
The documentation obligation attaches to cross-border related-party dealings. Domestic intra-group transactions do not, on their own, trigger the documentation requirement, although they remain subject to the arm’s length principle in substance.
Distinctive features of the French regime
The defining feature of the French regime is the separate annual Transfer Pricing Statement filed on Form 2257-SD. This is an abridged disclosure of the group’s principal intra-group flows and the methods applied, and it is filed with the tax authority within six months of the tax return deadline. It sits alongside, and does not replace, the full Master File and Local File, which remain produced on request. An entity above the threshold therefore faces both an active annual filing and a contingent production obligation.
France also recognises a narrow safe harbour for intra-group financing. A French borrower that pays interest at or below a published reference rate is treated as meeting the arm’s length standard on that rate without further demonstration, although a higher rate may still be defended on the basis of the borrower’s own credit profile.
Benchmarking and comparables
French comparables are preferred where the tested party is French, but pan-European comparable sets are accepted in practice. Multi-year testing over a three-year period is the expected approach. A fresh benchmarking search is not required every year: French administrative guidance permits a search to be retained and rolled forward with annual financial updates, provided the operating conditions of the tested party remain unchanged. The limitation period for transfer pricing adjustments follows the general corporate tax rule, which is generally three years from the end of the financial year.
Frequently asked questions
Does the Transfer Pricing Statement on Form 2257-SD replace the Master File and Local File in France?
No. The statement is a separate annual disclosure filed with the return. The full Master File and Local File remain a distinct obligation, prepared contemporaneously and produced within 30 days of a request during an audit.
Is a BEPS Action 13 format report sufficient for penalty protection in France?
A report in the BEPS Action 13 format is generally accepted as the basis for the documentation, although the financial data it contains may need to be supplemented to satisfy the French content requirements.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.