Enhanced Monitoring Report on the Implementation of the Standard on Transparency and Exchange of Information on Request 2025

France

France joined the Global Forum in 2009. France underwent its Second Round of EOIR Peer Review in 2018 (France’s 2018 Report),1 which assessed its legal and regulatory framework in force as at 5 January 2018 and its practical implementation, including in respect of EOI requests received and sent during the review period from 1 October 2013 to 30 September 2016. France received an overall rating of Compliant and the individual Elements were rated as follows:

 

	A.1	A.2	A.3	B.1	B.2	C.1	C.2	C.3	C.4	C.5	Overall
Determinations	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	i.p.	n.a.	C
Ratings	C	C	C	C	C	C	C	C	C	LC

Status of implementation of recommendations issued in the peer review report

France received one in-box recommendation in relation to Element C.5.

This monitoring report assesses the actions taken by France to address the recommendation issued in its EOIR Peer Review Report and the peer input received for the monitoring period 2023-2024.

The report concludes that the recommendation is “in the process of being addressed” and advises on actions required. In addition, a new recommendation has been added following the analysis of the peer input received on France (see EOIR experience and next steps sections).

Element C.5: Effective exchange of information

1. Timeliness of responses and provision of status updates

 

Recommendation (C.5, practice)	France is recommended to rapidly put in place a system to gather the requested information in a timely manner and inform the requesting jurisdictions of the status of their EOI request when the competent authority is not in a position to respond within 90 days.
Underlying factor	The internal processes within the tax administration do not always ensure the collection of the requested information in a timely manner and France rarely informs the requesting jurisdictions of the status of their EOI request when the competent authority is not in a position to respond within 90 days. (see paragraphs 318 to 234 of France’s 2018 Report for more information)
Summary of actions reported	In July 2020, France put in place a new IT tool to send acknowledgements of receipt of new EOI requests; reminders to the operational departments in charge of gathering the requested information, and reminders to send status updates within 90 days, when the information is not yet provided. Further improvement to the IT tool is being worked on to ensure systematic sending of status updates where required. Awareness-raising and training actions have been taken on EOIR. In May 2023, France put in place an Action Plan to accelerate the handling of EOI requests, with the objective of sending 70% of answers within 90 days.
Conclusions	France has made progress to address the recommendation. The part of the recommendation related to timeliness of answers has been addressed and the organisational problems identified in the 2018 Report have been solved. France is still working on addressing the part of the recommendation related to the provision of status updates. It should report further progress in the next self-assessment.
Status determined	In the process of being addressed
Actions required	In the next self-assessment, France should – Report actions taken to systematically provide status updates in all EOI requests where a response could not be provided within 90 days. Provide updated timeliness statistics for the corresponding monitoring period, according to paragraph 29 of the Enhanced Monitoring Methodology.

EOIR experience

Over the monitoring period, France received 3 512 requests and sent 9 857 requests. Belgium, Tunisia and Poland were the top three partners in respect of incoming requests. Switzerland, Germany and Luxembourg were the key partners in respect of outgoing requests. France reported providing full and final responses in 99% of all the received requests and indicated 1% as pending requests.

Twenty-five members provided peer input on France. Peers reported general satisfaction in respect of their EOIR experience with France. Some peers noted that the provision of status updates when information cannot be exchanged within 90 days of the request was not systematic, which is acknowledged by France. There is a pre-existing recommendation on the issue of systematic provision of status updates, and France is recommended to continue improving its communication on the matter.

Eight peers noted having asked for clarifications on requests received from France. Most of them indicated that they were satisfied with the quality of the requests sent from France and did not raise any concerns about the response times to their requests for clarification, with some partners explicitly stating that clarifications were sent by France within a reasonable time frame. One peer noted that while the EOI requests received from France were satisfactory, there was room for improvement as it noted delays in receiving responses to its requests for clarifications. Another peer also mentioned that sometimes it had to follow up with France in order to obtain clarifications.

While partners are generally satisfied with their relationship with France, the overall analysis of peer input shows that regarding France’s outgoing requests there is room to improve the way France communicates with its partners, particularly when clarifications are needed, and France is unable to provide them in a timely manner. In this regard, France is recommended to improve the communication with its EOI partners in relation to the handling of French outgoing EOI requests, notably by providing timely responses to requests for clarification sent by its peers. In its next self-assessment, France should indicate the measures taken to address this recommendation.

New developments having a bearing on the EOIR standard

France has reported progress in the implementation of a central beneficial ownership register. As this development could have a bearing on EOIR, France is invited to provide more details on the new development.

Next steps

France should continue taking actions towards implementing the standard effectively.

Under the first round of enhanced monitoring, a new recommendation is issued to France.

2. Improve communication with partners in relation to the handling of French outgoing EOI requests

 

Recommendation (C.5, practice)	France is recommended to improve the communication with its EOI partners in relation to the handling of French outgoing EOI requests, notably by providing timely responses to requests for clarification sent by its peers.
Underlying factor	In respect of requests sent by France, while most partners are generally satisfied with the promptness of communication and quality of requests, some peers reported delays in receiving responses to their requests for clarifications, which affected the effectiveness of exchange of information. Therefore, there is scope for enhancing communication with the partners.

The following next steps are expected from France:

• Submit the next self-assessment, including on the new recommendation issued, in 2028 under the second round of enhanced monitoring.

Views/response of the monitored jurisdiction

France would like to thank the Global Forum Secretariat for its support and attentiveness throughout the enhanced monitoring process, as well as the members of the Peer Review and Monitoring Group and all of its partners for their input.

France agrees with the conclusions of the monitoring report, takes note of the recommendations addressed to it, and reiterates its commitment to work to remedy the weaknesses identified in order to continue to ensure the overall effectiveness of exchange of information on request.

Note

← 1.  OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: France 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD Publishing, Paris, https://doi.org/10.1787/9789264291058-en.