France issues first GloBE payment notice for 2026, requiring multinational groups to submit notification, GloBE Information Return and top-up tax. Entities can centralise filing or designate another group entity to meet obligations, with deadlines set for May 2025 and June 2026.

RF Report

France has issued the GloBE payment notice that multinational enterprises liable for top-up tax under the GloBE Pillar Two rules must submit for the first time in 2026.

All companies belonging to a group within the scope of Pillar Two rules must fulfil the three following reporting obligations:

  1. Notification form pursuant to Article 223 WW-I of the French General Tax Code (CGI): the notification (form n° 2065-INT-SD) is filed in the corporate income tax return (corporate income tax, business profits tax, or real estate income tax).

It must be filed annually. It can be modified later, if needed.
The information notified (entity responsible for filing and paying) will allow access to online filing services for the GloBe Information Return and the Notice of top-up tax liability to the self designed entity.
Quality of identification and designation data reported both for filing and paying are key to secure an easy reporting process for companies in scope and to switch off local filing obligation by each constitutive entity of the group in France.

  1. GloBe Information Return (form n°2259-SD) pursuant to Article 223 WW-II of the CGI, must be submitted in an electronic form within fifteen months following the end of the fiscal year to which it relates (or within eighteen months following the end of the fiscal year in which the group and/or the filing constituent entity first enters the scope of Pillar 2 rules).
    Self designed entity will be responsible and liable for filing and for compliance reporting in the DGFIP portal. Local filing by each CE of the group in France will be switched off when a local or central designated entity will have fulfilled the GIR reporting obligation in France or abroad. Central filing abroad is conditioned to an active exchange agreement.
  2. Notice of payment (form n°2272-SD), is both a statement of liability between constitutive entities /ultimate parent entity and a notice of payment to file along payment wiring.

It must be filed within fifteen months after the end of the fiscal year to which it relates (or within eighteen months of the end of the fiscal year in which the group and/or the constituent entity first falls within the scope of Pillar 2 rules). Top up tax is wired electronically, in support of the notice of payment.

Exceptions:

  1. Exemption from filing the GloBe Information Return (GIR)
    An entity in scope of Pillar 2 rules may be exempted from filing the GIR when, in accordance with Article 223 WW bis of the CGI, it designated in its notification another surrogate entity (local or abroad) in its group for filing the GIR instead. There can only be one and the same designated entity by jurisdiction and this designation must be consistent between all the domestic entities of the group.
    Only the self designated entities will be registered in DGFIP system for filing and or paying and will be able to connect to DGFIP portal to fulfil GIR reporting and
    Paying requirements.

Information on the GloBe Information Return (GIR) filing process:

Local filing is the default rule, the principle is each and every entity of the group should file a GIR in each jurisdiction where the group operate but central filing mechanisms are provided to switch off the local filing obligation.

To switch off local filing, the group can opt either for:

  • a designated local entity that will file in France for all the French CE of the group
    or
  • a designated entity, usually the UPE, that will file in France or abroad according to the central filing mechanism for all the entities of the group world wide.

Central filing mechanism is conditioned to the existence of a valid exchange agreement with the jurisdiction of location of the group constitutive entities in order to allow the exchange of GIR by tax administrations.

The designation mechanism for French entities is done in the notification form.

To simplify the GMT reporting obligations for entities in scope, designation by each CE of the Groups has to be consistent and aligned whether they opt for local filing, filing a single GIR per jurisdiction, or a central filing with a single GIR for the whole group.

If the GIR is filed centrally, it may be lodged in France or abroad. However, central reporting abroad is permitted only when a bilateral or multilateral automatic exchange of information (AEOI) agreement under GloBe – Pillar 2 between France and the jurisdiction of filing is in force. When that is the case, information in the GIR lodged abroad that is relevant to France will be transmitted to the French tax administration via AEOI.

Likewise, GIR centrally filed in France for entities located abroad will, provided that a bilateral or multilateral AEOI agreement under GloBe – Pillar 2 is in force between France and the jurisdiction where these entities are located, be transmitted via AEOI to the relevant authorities.

  1. Exemption from filing the notice of payment
    Top-up-tax is paid in support of the notice of payment. Therefore, any entity required to pay top-up-tax must file a notice of payment to enable payment.
    An entity in scope may be exempted from filing the notice of payment when:
  • It has no top up tax to pay and did not designate itself as the entity for filing the notification
  • or if it designated, in its notification form, another entity located in France to pay the top up tax on its behalf

In situation where a self designated entity for filing the notice of payment has no top up tax to pay, it can either modify its notification or file a notice of payment with zero.

Information regarding options for designating an entity, within the group, responsible for paying top-up-tax and therefore for filing the notice of payment:

These options depend on the top-up-tax due:

  • Ultimate parent entity is always liable for the IIR (Income Inclusion Rule) and must therefore always file a notice of payment when an IIR has to be paid in France,
  • Any other entity than the liable entity or the ultimate parent entity can be designated to fulfil the filing and payment obligations regarding DMTT (domestic top-up-tax) and UTPR (Under-Taxed Profits Rule), on behalf of the liable constituent entities. The constituent entities liable for DMTT and/or UTPR may designate, in their notification form, another entity of the group located in France for filing the notice of payment and paying top-up-tax, in accordance with Article 1679 decies-I, 3° of the CGI.

Schedule and filing deadlines:

Regarding the first fiscal year beginning on or after December 31st, 2023, the filing deadlines are as follows:

  • Notification: no later than 20 May 2025. As an exception, for the first year, taxpayers whose fiscal year ends before 31  December 2024, must file the notification no later than May 20th, 2025, regardless of their income tax return category. In this case, the notification will be filed independently of any other formalities via their secure professional portal on the website www.impots.gouv.fr.
  • GloBe Information Return: no later than 30 June 2026, in accordance with Article 223 WW of the CGI.
  • Notice of payment (and top-up-tax payment): no later than 30 June 2026, in accordance with Article 1679 decies-I et II of the CGI.

Earlier, France issued Decree No. 2024-1126 on 4 December 2024 in the Official Gazette, which sets out the regulations for implementing the Pillar Two global minimum tax (GloBE) rules as part of the Finance Law for 2024 (Law No. 2023-1322 of 29 December 2023).