France clears way to swap GloBE tax returns with peers

Law No. 2026-963Legifrance of 19 October 2026Legifrance contains a single articleLegifrance: approval of the multilateral agreement between competent authorities on the exchange of GloBE informationLegifrance, signed in Paris on 9 July 2025Legifrance and annexed to the law, is authorised.

The authorisation matters for the filing mechanics of the global minimum tax. Under the French rules, every constituent entity in France of a group within the complementary-tax scope must, after notifying, file an information return and a liquidation slip in dematerialised form. By way of derogation, the entities may designate a single entity within the group to file the information return for the whole group — and that entity may be located in France or in a State that has concluded with France an agreement for the automatic exchange of complementary-tax information returns. The authorised agreement is the instrument that builds that exchange network.

The backdrop is the Pillar Two coordinated minimum-tax system. Work in the OECD/G20 base-erosion and profit-shifting project led to the global anti-base-erosion model rules, known as the GloBE – Pillar Two model, approved on 14 December 2021 by the OECD/G20 Inclusive Framework. The European Union followed with Directive 2022/2523 of 14 December 2022 ensuring a global minimum level of taxation for multinational groups and large-scale domestic groups. France transposed the directive through Article 33 of the Finance Law for 2024, completed by Article 53 of the Finance Law for 2025, setting the worldwide minimum rate at 15% for profits of multinational groups with a French presence and of large domestic groups operating solely in France.

The complementary tax, distinct from corporation tax, applies for financial years opened from 31 December 2023, except for the undertaxed-profits rule, which applies from 31 December 2024. It covers entities in France that belong to a group with consolidated turnover of at least €750 million in at least two of the four years preceding the year in question. Groups in scope face the new filing obligations from the years opened 31 December 2023, meaning in practice from May 2025, with the return's content set by decree and payment by remote transfer against the liquidation slip.

The legal basis is Law No. 2026-963 of 19 October 2026, whose single article authorises approval of the multilateral competent authority agreement on the exchange of GloBE information signed in Paris on 9 July 2025.