France: Multiple reporting exemption regarding public CbC transposed into law
Effective as of December 28, 2025
The French authorities have released new reporting obligation modalities regarding public country-by-country (CbC) reports. The multiple reporting exemption has now been transposed into French law as of December 28, 2025. Additionally, the public CbC report may be prepared in any official language of the EU (there is no longer an obligation to prepare the report in French).
The public CbC reporting directive provides that member states will not apply the reporting obligation to EU subsidiaries or branches, when a report on income tax information is drawn up by an ultimate parent undertaking or standalone undertaking that is not governed by the law of a member state, provided the following criteria are met:
- The report is made accessible to the public, free of charge, and in an electronic, machine-readable format
- Within 12 months following the end of the relevant financial year, it identifies the name and the registered office of a single subsidiary undertaking, or the name and the address of a single branch governed by the law of a member state, which is designated to submit the report to the relevant national commercial register
In other words, the EU subsidiaries and branches are exempt from their obligations if the non-EU parent has published the report on its website and has assigned one of the EU subsidiaries or branches to file the report with their national commercial register.
The multiple reporting exemption had not been transposed into French law until now, even though member states do not have the possibility to opt out of this exception.
For more information, contact a KPMG professional at KPMG Avocats:
Marie-Pierre Hoo | mhoo@kpmgavocats.fr
Alexandra Baudart | abaudart@kpmgavocats.fr