France’s tax administration has confirmed support for a transitional OECD-aligned approach to the centralised filing and exchange of the GloBE Information Return, applying relief for reporting deadlines up to 31 December 2026.
France’s Directorate General of Public Finances (DGFiP) has clarified its position on the centralised filing and exchange of the GloBE Information Return (GIR), confirming its intention to apply a transitional relief framework aligned with the OECD’s agreement published on 18 May 2026.
The OECD’s publication set out a common understanding negotiated by certain jurisdictions implementing Pillar Two on the centralised filing and exchange of the GIR. France has indicated support for this internationally coordinated approach, which is intended to provide certainty during the initial phase of Pillar Two reporting obligations and the first reporting cycle.
The transitional relief is intended to apply to returns with a filing deadline no later than 31 December 2026.
The DGFiP stated that a consistent, coordinated and pragmatic implementation of Pillar Two reporting obligations is necessary to ensure certainty for affected groups.
During the transitional period, the DGFiP accepts the principle of centralised filing of the GIR, whether by the ultimate parent entity or a designated group entity, provided it is submitted by the filing deadline in one of the jurisdictions listed in the annex.
Where these conditions are met, French constituent entities of a multinational group will, in principle, not be required to file a local GIR, provided that the return can be transmitted to the French tax administration within a maximum of six months following the filing deadline.
The French tax administration also stated that it will take into account good-faith efforts made by multinational groups to comply with reporting obligations under the centralised filing mechanism, provided that notification obligations in France are met and centralised filing is completed within the relevant deadlines.
Where the absence of filing in France results solely from the transitional GIR filing and exchange approach, this will be considered in assessing administrative consequences, including penalties and sanctions.
If the GIR has been centrally filed in one of the jurisdictions listed in the annex and is received by the DGFiP within the six-month period, the DGFiP will not impose a local filing requirement and will adopt a lenient approach regarding applicable sanctions and penalties.
If the administration does not receive the centrally filed GIR within six months after the filing deadline, it may contact the group to enforce the local filing obligation and indicate that late filing penalties will apply until obligations in France are fulfilled.
The DGFiP added that the transitional approach will not apply to jurisdictions that are not participating in the agreement and are not listed in the annex.
The DGFiP GIR reporting portal opened on 4 May 2026, while the testing portal opened on 8 April 2026.
For further information on Pillar Two reporting obligations and filing procedures, reference is made to the DGFiP information pages and user guidance covering reporting obligations, filing of the GloBE Information Return (GIR) and settlement statement, and XML reporting requirements.
The list of jurisdictions identified as having, or being committed to having, the legal and operational instruments necessary for the effective exchange of GIR filings is as follows:
South Africa; Germany; Australia; Austria; Barbados; Belgium; Bulgaria; Canada; South Korea; Croatia; Denmark; Spain; Finland; France; Gibraltar; Greece; Hungary; Ireland; Italy; Japan; Liechtenstein; Luxembourg; Norway; Netherlands; Poland; Portugal; United Kingdom; Romania; Slovenia; Sweden; Switzerland; Czechia; Turkey.
Earlier, France’s tax authority updated its guidance on the Pillar Two global minimum tax to clarify reporting requirements under the complementary tax regime introduced in the 2024 Finance Law on 9 December 2025.
