The French tax authorities introduced a Form n°2065-INT-SD intended for entities subject to the French Pillar Two law on 24 January 2025.

The form was previously used to submit the Country-by-Country (CbC) reporting notification alongside the annual tax return. The updated version now serves both as the CbC notification and as a notification for the Pillar 2 global minimum tax rules, also submitted with the annual tax return.

The form requires details such as the name, address, and tax number of the ultimate parent entity (UPE), as well as the entity responsible for filing the group information return (GIR), if different from the UPE.
It also asks for information about the French entity in charge of submitting the qualified domestic minimum top-up tax (QDMTT) and paying any additional top-up tax, if applicable.

A specific section of the form focuses on the domestic minimum top-up tax (DMTT) due by French investment entities.

The form must be submitted with the corporate income tax (CIT) return, which is due within three months after the end of the fiscal year. For entities with a fiscal year ending 31 December 2024, the deadline is 19 May 2025, if the CIT return is filed electronically.

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).

France released its Finance Law for 2024 (Law no. 2023-1322) in the Official Gazette on 30 December 2023, along with the Constitutional Court’s review, affirming the constitutionality of key tax measures.