Transfer pricing declaration

Companies with a fiscal year ending on December 31 and whose tax-free annual revenues are equal or greater 50 million euros must declare their transfer pricing policy every year.
Each year, companies belonging to groups may be required to file electronically a declaration on their transfer pricing policy, using tax form n° 2257, within 6 months following the deadline for filing their corporate tax return.

This special declaration applies to companies established in France that:
– have annual sales excluding taxes or gross assets on their balance sheet equal to or greater than 50 million euros.
– or hold at the end of the fiscal year, directly or indirectly, more than 50% of the capital or voting rights of a company that meets the above-mentioned financial condition.
– or are held, in the same way, by such a company.
– or belong to an integrated tax group of which at least one company satisfies one of the 3 previous cases.

This documentation must be drawn up by companies as defined above, but whose annual turnover before tax or gross assets in the balance sheet are at least equal to 400 million euros.

The declaration is a simplified version of the transfer pricing documentation. It includes general information on the group of associated enterprises and information specific to the reporting enterprise. However, companies that do not carry out any transactions with related entities of the group or whose transactions do not exceed €100,000 per type of flow (sales, provision of services, commissions, etc.) are exempted from reporting.