France published BOI-IMG guidance regarding the implementation of the 15% global minimum tax for large domestic and multinational groups.

The French tax authorities published the guidance (BOI-IMG), on 8 October 2025, regarding the implementation of the global minimum tax rules for multinational and large domestic groups, as set out in Directive (EU) 2022/2523. The rules were transposed into French law through Finance Laws for 2024 and 2025, codified in Articles 223 VJ to 223 WZ of the General Tax Code.

The legislation applies to fiscal years starting from 31 December 2023 and establishes a minimum 15% tax rate on the profits of:

  • Multinational groups with entities in France
  • Large domestic groups operating solely in France

Article 223 VJ of the CGI provides that the multinational enterprise groups and national groups referred to in Article 223 VL of the CGI are subject to an annual minimum tax. This takes the form of a supplementary tax determined, depending on the case, according to:

  • the income inclusion rule;
  • the undertaxed profits rule;
  • the rules for the national top-up tax.

This series addresses successively:

  • Definitions specific to global group taxation (BOI-IMG-DEF);
  • Scope and territoriality (BOI-IMG-CHAMP);
  • Protective regimes (BOI-IMG-RP, in drafting);
  • Methods for determining the effective tax rate (BOI-IMG-TEI, in drafting);
  • Assessment of the supplementary tax (BOI-IMG-LIQ, in drafting);
  • Taxpayer and collection procedures for the supplementary tax (BOI-IMG-RED, in drafting);
  • Rules relating to group organisation and restructurings (BOI-IMG-REORG, in drafting);
  • Special regimes (BOI-IMG-PART, in drafting);
  • Transitional rules applicable upon entering the scope of the supplementary tax (BOI-IMG-TRANS, in drafting);
  • Reporting and payment obligations (BOI-IMG-DECLA, in drafting);
  • Collection, audits, and dispute procedures (BOI-IMG-PROCD, in drafting).

Earlier, the French tax authority issued a notice on 12 September 2025 reminding French entities that are part of a multinational enterprise (MNE) group subject to the Pillar 2 global minimum tax to complete box II of Form n°2065-INT-SD.