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France imposes three crucial requirements on certain groups regarding transfer pricing: documentation (A), annual declaration (B), and country-by-country reporting (CbCR) (C). These obligations were put in place to prevent profit shifting abroad within groups entities and reduce the risks of aggressive tax planning. The assessment of the different scopes of application is complex making it difficult to identify the requirements lying with the taxpayers.

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Summarized French TP requirements

Summarized French TP requirements

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