France details Pillar 2 filing duties for groups over €750m revenue

French constituent entities of multinational and large domestic groups whose consolidated revenue reaches at least 750 million euros in at least two of the four financial years preceding the year in questionImpots fall within the global minimum taxImpots, whatever their own size, revenue or profit and wherever the ultimate parent is resident. France levies a 15% minimum tax that is distinct from corporation taxImpots, collected through three top-up taxes: the qualified domestic minimum top-up tax, the income inclusion rule and the undertaxed profits ruleImpots.

Compliance runs on three filings. Every French entity in scope files the 2065-INT-SD membership notification annexed to its results return, in EDI-TDFC format at the same time as the tax bundleImpots; corrective notifications filed after the results return are accepted. The Globe Information Return (form 2259-SD) is filed electronically within fifteen months of the year end, eighteen months for the first year the group enters the scopeImpots. By default each entity files, but the group may designate a single constituent entity to file centrallyImpots, provided it sits in France or in a state that has an automatic information exchange agreement with France. The 2272-SD liquidation statement, supporting payment of the top-up tax by télérèglement, follows the same fifteen/eighteen-month timetable and gives rise to no advance instalmentsImpots. Notification and GIR duties apply even where the group benefits from safe-harbour reliefImpots.

United States-headed groups that meet the threshold are in scope for financial years 2024 and 2025 on normal termsImpots: their French subsidiaries file the notification, the GIR and the liquidation statement and face all three top-up taxesImpots. The OECD Side-by-Side package, which lets groups whose ultimate parent sits in an eligible state such as the United States neutralise the income inclusion and undertaxed profits rules where the conditions are met and the regime is electedImpots, applies for financial years opened on or after 1 January 2026Impots. A GIR is still filed for the group, with an arrangement sparing it the data on United States entities and any income inclusion or undertaxed profits computation in their respectImpots.

Groups in the start-up phase of international activity get a five-year exemption from the income inclusion and undertaxed profits top-up taxesImpots, and large domestic groups newly entering the scope get a five-year exemption from the income inclusion taxLegifrance. The exemption does not cover the domestic minimum tax: each French constituent entity remains liable for the qualified domestic top-up tax under ordinary rules. And the income inclusion exemption covers only the portion attributable to low-taxed entities located in FranceImpots; a French ultimate parent remains liable under the income inclusion rule for its low-taxed subsidiaries outside FranceImpots.

Each entity liable for top-up tax files its own 2272-SD and pays what it owes, but one French constituent entity may be designated to file and pay the domestic minimum tax and the undertaxed profits tax for all French liable entitiesImpots, standing jointly liable for the duties, penalties and accessory costs. The income inclusion tax is always paid by the liable parent itself; where two entities are liable under that rule in France, each files separatelyImpots. Cyprus operates a qualified income inclusion rule for financial years beginning on or after 31 December 2023Impots, collects GIR filings from 31 May 2026 and exchanges them in time for the first exchange campaignImpots, so a group filing centrally in Cyprus faces no local GIR filing elsewhereImpots.

Legal basis: CGI articles 223 VJ to 223 WZ, in particular articles 223 VL (scope), 223 WF (domestic top-up tax), 223 WY (temporary exemption) and 223 WW (filing duties), transposing Directive (UE) 2022/2523.