Section VII: Obligations of legal persons

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Article 223 quinquies C

French General Tax CodeIn force
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Updated 8 Nov 2023

I. - 1. A declaration including a country-by-country breakdown of the group's profits and economic, accounting and tax aggregates, as well as information on the location and activity of the entities making it up, the content of which shall be set by decree, shall be submitted in dematerialised form, within twelve months of the end of the financial year, by legal entities established in France that meet the following criteria:

a) Draw up consolidated accounts;

b) Own or control, directly or indirectly, one or more legal entities established outside France or have branches there;

c) Have consolidated annual sales, excluding tax, of at least €750 million ;

d) Not be owned by one or more legal entities located in France and required to file this declaration, or established outside France and required to file a similar declaration under foreign regulations.

2. A legal entity established in France which is directly or indirectly owned or controlled by a legal entity established in a State or territory not included in the list referred to in II and which would be required to file the declaration referred to in 1 if it were established in France shall file the declaration:

a) If it has been designated by the group for this purpose and has informed the tax authorities; or

b) If it cannot demonstrate that another entity of the group, located in France or in a country or territory included on the list mentioned in II, has been designated for this purpose.

3. The declaration referred to in the first paragraph of 1 may, subject to reciprocity, be the subject of automatic exchange with States or territories that have concluded an agreement with France to this effect.

II. - The list of States or territories which have adopted regulations making it compulsory to submit a country-by-country declaration similar to that set out in 1 of I, which have concluded an agreement with France allowing automatic exchange of country-by-country declarations and which comply with the obligations resulting from this agreement shall be determined by an order.

>I.
Mariela Petrova

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Common Questions

Working with a corporate lawyer in France — Q&A

Any time a strategic decision changes how the company is owned, governed or contractually bound — incorporation, fundraising, M&A, restructuring, shareholder agreements, or major commercial contracts. Earlier engagement always costs less than later remediation.

A notary (notaire) is a public officer who authenticates specific deeds (mainly real-estate transfers and certain family-law acts). A corporate lawyer (avocat) advises on strategy, negotiates and drafts company documents, and represents you in disputes. The two roles complement rather than overlap.

Yes — most of our clients are foreign suppliers, investors or holding entities. We bridge the gap between French law and your home jurisdiction's expectations and deliver everything bilingually.

The SAS (Société par Actions Simplifiée) is the default choice for most international structures: flexible governance, single shareholder allowed, no minimum capital, and works cleanly with foreign holding entities. We assess SARL, SA, SCI on the merits when the situation calls for it.

Yes — communications with a French avocat are protected by the secret professionnel (Article 66-5 of the Law of 31 December 1971). This protection is broader than the common-law attorney-client privilege and applies to written and oral exchanges.

We work on fixed fees for clearly scoped engagements (incorporation, contract drafting, audits) and on monthly retainers for ongoing advisory. Hourly billing is the exception, not the default. You always know the cost before work starts.

Typical timeline is 2–3 weeks from KYC kick-off to RCS registration, assuming standard documentation. Holding-company structures, foreign-shareholder identification or in-kind contributions can extend this — we flag the gating items at the first meeting.

Absolutely. We routinely coordinate with your in-house counsel, expert-comptable or notaire — pragmatic collaboration is the norm, not the exception. We send them everything they need to do their part without duplicating work.

Mariela Petrova

Mariela Petrova

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15+ Years In Corporate Practice

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Communications protected by professional secrecy — secret professionnel de l'avocat, Article 66-5 of the Law of 31 December 1971.

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