France: Obligations between taxpayers and FTA under advance pricing agreements (APAs)

Confidentiality rules, retroactivity options for roll-back requests, and revised examination period

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July 17, 2025

The French Tax Authorities (FTA) published a new Charter on April 16, 2025, applicable to the relationship between companies and the national public finance department (DGFIP) in the framework of advance pricing agreements (APAs).

Background

The government's roadmap for combating public finance fraud, released on June 2, 2023, increased pressure on taxpayers. In response, the APA team was expanded to reduce processing times for APA requests, simplifying management. Despite this, an amendment requiring an APA for any French entity with a turnover of €50 million or more, belonging to an international group, was deemed unrealistic due to resource constraints and lengthy procedures.

FTA Charter

The Charter, optional in 2025, summarizes reciprocal obligations between taxpayers and the FTA, capturing the spirit and pace of work according to respective timetables. It incorporates innovations from FTA guidelines, establishing an effective examination framework.

Key features include confidentiality rules, retroactivity options for roll-back requests limited to three years, and a revised examination period. Companies are invited to arrange preliminary meetings with the FTA before submitting a letter of intent, with specific timelines for application submissions.

Read a July 2025 report prepared by the KPMG member firm in France

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