Tax authorities issued a second set of Pillar 2 guidelines clarifying transitional rules and temporary IIR/UTPR exemptions.
France’s tax authorities have released a second set of guidelines on 3 December 2025 covering the application of the Pillar 2 global minimum tax (GloBE) rules for multinational and large domestic groups.
The new guidance provides clarifications on transitional rules, including the calculation of deferred taxes and transferred assets during the transition year and subsequent periods (BOI-IMG-TRANS-10). It also outlines a temporary IIR/UTPR exemption for groups in the early stages of international operations (BOI-IMG-TRANS-20).
Earlier, 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.