9th july 2026
The French authorities have issued a long-awaited ministerial order implementing the public country-by-country requirements as regards the template and electronic filing format of the report on corporate income tax.
The said order requires that the public CbCR report:
- be drawn up according to the common EU template set out in Annex I to Regulation (EU) 2024/2952 (article A. 232-3 of the French commercial code);
- be filed in an electronic declaration format in line with Article 4 of Regulation (EU) 2024/2952 (article A. 232-4 of the French commercial code).
As a transitional measure, the report may be prepared in a free electronic format (non-standardized) for financial years beginning between 1 January 2025 and 31 December 2026 (article A. 232-5 of the French commercial code).
The order applies to financial years beginning on or after 1 January 2025, with the derogation under Article A. 232-5 limited to financial years beginning between 1 January 2025 and 31 December 2026.
Read our alert about the transposition of the EU public CbCR directive into French law for further background on the underlying reporting obligation.
