France has issued new guidance tightening transfer pricing compliance for multinational groups. From financial years starting on January 1, 2024, the turnover threshold for applying transfer pricing documentation and control rules is lowered to €150 million, down from €400 million.
The guidance also raises the minimum fine for failing to provide required transfer pricing documentation to €50,000, significantly increasing the cost of noncompliance. It sets out how the tax authorities will review indirect profit transfers between related companies and explains the procedures used to challenge transfer prices. In addition, it confirms that transfer pricing and beneficial ownership information may be shared automatically with foreign tax authorities.
To access the Guidance, click here.
France’s tax authority has clarified how multinational groups must comply with the global minimum tax under OECD Pillar Two. Companies covered by the supplementary tax must file their information returns electronically within 15 months after the end of the financial year. For the first year in which the group or entity falls under the rules, the deadline is extended to 18 months. The guidance also explains which entities and income fall within the scope of the supplementary tax. In addition, it outlines how the income inclusion rule and the undertaxed profits rule work, helping groups understand when France can collect top-up tax on low-taxed profits.
To learn more on the Announcement, click here.
France’s tax authority reported a significant rise in recovered unpaid taxes for 2024, led by transfer pricing and other international tax adjustments. According to the Directorate General of Public Finances, business tax recoveries through audits grew by 23%, reaching €5.2 billion. Transfer pricing cases accounted for 64% of that total—around €3.3 billion. The agency argued that this revenue is a result of stronger audits conducted on how multinational companies value transactions between related entities, leading often to profit shifting toward lower-tax countries.
To access the official reporting, click here.
On July 23, 2025 France’s General Directorate of Public Finance published guidance guiding the implementation of OECD’s Pillar One Amount B principles. The document outlines how France will handle the scope of transactions and methods for adopting transfer prices under Amount B. France will honor results based on Amount B for fiscal years starting on or after January 1, but only when applied by a jurisdiction that has a tax treaty with France and qualifies as a “covered jurisdiction.” As of June 30, no such jurisdictions have adopted Amount B. The guidance also confirms that Amount B outcomes are seen as valid estimates of arm’s length pricing, but if used by non-covered jurisdictions, they have no legal weight in France.