Article 1649 AD of the French General Tax Code
I.-A declaration of a cross-border scheme is filed with the tax authorities, in dematerialised form, by the intermediary involved in implementing the scheme or by the taxpayer concerned. II.-For the purposes of applying the provisions of I, any scheme taking the form of an agreement, arrangement or plan, whether legally enforceable or not, involving France and another State, whether a member of the European Union or not, is deemed to…