Failure to e-file Form n°2065-INT-SD may result in a fine of EUR 50,000 under Article 1729 F bis of the French Tax Code (CGI).
The French tax authority issued a notice on 12 September 2025 reminding French entities that are part of a multinational enterprise (MNE) group subject to the Pillar 2 global minimum tax to complete box II of Form n°2065-INT-SD.
Failure to e-file the form may result in a fine of EUR 50,000 under Article 1729 F bis of the French Tax Code (CGI).
The notice also states that reminders have been sent via email to entities that either failed to submit the form or did not fill in box II. Taxpayers are urged to comply with these reporting requirements promptly.
Additionally, emails have been sent to those who made errors, requesting corrections to be submitted as soon as possible, and no later than 30 September 2025.
Initially, this form was used for Country-by-Country (CbC) reporting (box I). However, a revised version released in January 2025 added box II to accommodate reporting for the global minimum tax.
Earlier, France issued Decree No. 2024-1126 on 4 December 2024 in the Official Gazette, which set out the regulations for implementing the Pillar 2 global minimum tax (GloBE) rules as part of the Finance Law for 2024 (Law No. 2023-1322 of 29 December 2023).
