Executive summary

On 30 March 2022, the French Tax Authority (FTA) published new guidelines regarding the reporting obligations of trustees (often referred as the “French mini–Foreign Account Tax Compliance Act- FATCA” rules) provided under Article 1649 AB of the French tax code (FTC) and Articles 369 to 369 AB of Annex II to the FTC.

In their guidelines, the FTA notably address the notion of Frenc…