In accordance with Country Law 2025-16, the DSF has opened the declaration portal for cross-border tax devices (dispositifs transfrontières). Taxpayers who have implemented or participated in cross-border arrangements that meet defined hallmarks of aggressive tax planning must disclose these arrangements. The regime mirrors the EU’s DAC6 directive, requiring intermediaries and taxpayers to report within 30 days of the arrangement being made available or implemented. The DSF has published a list of hallmarks and a user guide for the electronic filing system.
Key Takeaways
- Mandatory Disclosure: Arrangements with hallmarks such as confidentiality clauses, standardized documentation, or loss shifting must be reported.
- Intermediary Obligations: Tax advisors, lawyers, and banks involved in designing or marketing such arrangements bear primary reporting responsibility.
- Penalties: Failure to declare attracts fines proportional to the tax advantage sought, with potential criminal sanctions for repeated offenses.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement