We remind you that, during the month of November, companies that closed the fiscal year 2017 in December, must present the model 232 of informative declaration of related operations and of operations related to countries or territories considered as tax havens.

Model 232 includes three areas:

Related operations carried out during the year 2017.

The companies required to submit them are those that meet any of the following requirements:

• That the aggregate amount of transactions with the same person or related entity exceeds € 250,000.
• That the combined amount of the following types of specific operations exceed € 100,000
  • those made with entrepreneurs in objective estimation who hold at least 25% of the capital;
  • those relating to business transmission;
  • those relating to the transfer of shares or unlisted shares;
  • those relating to operations on real estate;
  • those relating to operations on intangible assets.
• That the aggregate amount of transactions with related companies exceeds 50% of the entity's turnover,

With the following exceptions:

• the operations within the same fiscal group;
• the operations carried out by AIEs and UTEs with their members;
• the operations carried out in the scope of OPA and OPV of securities;
• operations that do not exceed the thresholds indicated above.

The declaration must identify the persons or entities linked to those that have operations, type of operation, amounts and valuation method. And obviously, this information must be consistent with the corresponding books of related operations and reports on transfer prices.

Transactions with persons or entities resident in tax havens, whether or not they are linked, regardless of the amount of the transactions.

Transactions with related parties to which the taxpayer has applied the reduction of Article 23 LIS (assignment of certain intangible assets -Pate box), whatever the amount of the transactions.

For more information about the model 232, or any other aspect related to the tax policy of your company, do not hesitate to contact us.