France has issued Decree No. 2024-1126 on 4 December 2024 in the Official Gazette, which sets out the regulations for implementing the Pillar Two global minimum tax (GloBE) rules as part of the Finance Law for 2024 (Law No. 2023-1322 of 29 December 2023).
Earlier, France released its Finance Law for 2024 (Law no. 2023-1322) in the Official Gazette on 30 December 2023, along with the Constitutional Court’s review, affirming the constitutionality of key tax measures.
A major highlight is the implementation of Council Directive (EU) 2022/2523 for Pillar Two global minimum tax was the inclusion of Pillar Two Income Inclusion Rule (IIR) and the Undertaxed Payment/Profit Rule (UTPR), ensuring a 15% minimum tax for MNE groups. The law also introduces a Qualified Domestic Minimum Top-Up Tax (QDMTT) for in-scope groups, applicable from 31 December 2023, with UTPR effective from 31 December 2024.