The French tax authority released updated guidance on the Pillar 2 global minimum tax, highlighting the release of the GloBE Information Return (Form 2259-SD) and providing detailed instructions for in-scope multinational enterprise (MNE) groups.
France’s tax authority has updated its guidance on the Pillar 2 global minimum tax to clarify reporting requirements under the complementary tax regime introduced in the 2024 Finance Law on 9 December 2025. The guidance highlights the release of the GloBE Information Return (Form 2259-SD) and provides detailed instructions for in-scope multinational enterprise (MNE) groups.
Under Article 223 WW-II of the French General Tax Code (CGI), entities that are part of groups subject to the complementary tax must submit Form 2259-SD electronically within 15 months of the end of the relevant fiscal year. For groups entering the scope of the tax for the first time, the return is due within 18 months. For most groups, the first applicable year ends 31 December 2024, making the initial deadline 30 June 2026. A test platform for submitting the form will open on 1 April 2026, followed by the official platform on 2 May 2026. A user guide and annexes—including XML tag specifications, a sample return, and validation checks—have also been published.
The complementary tax, transposed from Directive (EU) 2022/2523 into French law via Article 33 of Law No. 2023-1322, establishes a minimum tax rate of 15% on profits of MNE groups with a presence in France, as well as large domestic groups. It applies to companies with consolidated revenues of EUR 750 million or more in at least two of the four preceding financial years, excluding certain exempt entities.
Pillar 2 tax obligations in France are calculated using two primary mechanisms: the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR).
The IIR imposes the complementary tax on parent entities when constituent entities are under-taxed in their jurisdiction. The UTPR reallocates residual complementary tax to jurisdictions where the IIR cannot collect it, particularly if the parent entity’s country does not implement the Pillar 2 rules. The National Complementary Tax (INC) applies domestically to under-taxed French entities and offsets any IIR liability.
Effective tax rates are calculated for each jurisdiction as the ratio of covered taxes to “qualified” profit. Entities within France must submit an information return and a liquidation statement electronically. Groups may designate a single entity to file and pay on behalf of all constituent entities using Form 2065-INT-SD. Additional guidance addresses common errors and provides a full filing procedure.
France’s guidance aligns with OECD/G20 Base Erosion and Profit Shifting (BEPS) Pillar 2 rules, designed to ensure a minimum level of taxation for multinational groups and large domestic groups, reinforcing global efforts to address profit under-taxation.
