France

DAC6 - Reporting obligations

The European Union (EU) Directive 2018/822 of 25 May 2018 on the mandatory disclosure and automatic exchange of cross-border tax arrangements (so-called ‘DAC6’) was implemented in French tax law in articles 1649 AD to 1649 AH of the French tax code.

The DAC6 reporting obligations to local tax authorities focus on cross-border tax planning arrangements that meet characteristics or hallmarks intended to highlight risk of tax avoidance and enable more effective audits.

OECD Pillar 1 – France state of play

France has recently announced that it will not implement Amount B with respect to distribution subsidiaries established in France from January 2025, but reaffirmed its commitment to respect outcomes of Amount B were applied by designated ‘low-capacity jurisdictions’. An administrative instruction in this regard should be published by mid-2025. This decision is made pending further work and more visibility on the fate of Amount A.