France has updated its regulations to align with the EU public country‑by‑country (CbC) reporting directive, easing compliance for multinational groups and introducing the multiple reporting exemption.
France adopted new rules on 28 December 2025 to streamline compliance with the EU public CbC reporting directive (Directive (EU) 2021/2101), fully aligning national law with EU requirements and implementing the multiple reporting exemption.
The directive, effective for multinationals with annual global revenue above EUR 750 million, requires disclosure of corporate income tax information for each EU member state and for jurisdictions on the EU’s list of non-cooperative countries. Reports must be machine-readable, filed with an official EU register, and publicly accessible online for at least five years.
Under the directive, EU subsidiaries or branches are exempt from reporting if an ultimate parent undertaking (UPE) or a standalone undertaking outside the EU publishes the report, provided it is freely accessible in electronic, machine-readable format. Within 12 months after the financial year, the report must also identify a single EU subsidiary or branch responsible for filing with the national commercial register.
By adopting the multiple reporting exemption, France positions itself as a potentially attractive jurisdiction for centralised public CbC reporting. Companies must still confirm filing obligations, deadlines, and any applicable sanctions in each member state before selecting France as their reporting base.
Earlier, the French tax administration reported recurring mistakes in the filing of form 2065-INT-SD, which groups subject to country-by-country reporting (CbCR) and the global minimum tax (Pillar 2) must submit alongside their corporate income tax returns.
