The French Council of Ministers has approved the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), a Pillar Two mechanism under the OECD/G20 Inclusive Framework aimed at enabling automatic exchange of GloBE data and supporting the 15% global minimum tax framework for large multinational groups.
The French Council of Ministers approved the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) under Pillar Two of the OECD/G20 Inclusive Framework on BEPS on 27 May 2026.
The GIR MCAA is designed to facilitate the automatic exchange of GloBE Information Return (GIR) data between tax administrations. It is classified as a Qualifying Competent Authority Agreement under the Global Anti-Base Erosion (GloBE) Model Rules.
Under the GloBE Model Rules, multinational enterprise groups are required to file an annual GloBE Information Return (GIR), which sets out key tax and financial data used to apply the global minimum tax framework.
The agreement is intended to support centralised filing of the GIR by multinational enterprise groups, while enabling participating jurisdictions to automatically exchange the information. This is aimed at reducing compliance burdens and improving administrative coordination between tax authorities.
The proposal also forms part of the broader implementation of a global minimum tax of 15% on the profits of large multinational groups, as set out under Pillar Two arrangements.
The agreement will now require approval by the French Parliament before it can enter into force.
