The international tax reform under Pillar 2 sets a minimum global tax rate of 15% on the profits of multinational and large national groups operating in France. This rule, adopted by the EU and incorporated into French law, applies to companies with consolidated sales exceeding €750 million in at least two of the past four financial years.
What are the obligations for companies?
The groups concerned must comply with a rigorous disclosure process involving:
– A declaration of membership in a group subject to GloBE rules.
– Filing a detailed report on their effective tax rate and, if necessary, the payment of an additional tax.
– A statement of settlement in the event of additional taxation.
Transitional measures to make the transition easier
To facilitate compliance, a number of relaxations have been introduced:
✅ Temporary protection measures for certain companies under certain conditions.
✅ Option for de minimis exclusion for companies with low revenues and profits.
✅ Simplified statements until 2028 to reduce the administrative burden.
