The French Tax Administration has published the new form model N°2065-INT-SD. This measure includes new reporting obligations related to Pillar Two of the OECD’s BEPS Action Plan, aligning with European regulations and directly implemented in France. This change is crucial for multinationals and funds with a presence in the country. 

What is Pillar Two? 

Following the approval of Decree 2024-1126, companies established in France must provide additional information on the rules included in Pillar Two. Specifically, these entities must adapt to the measures established to ensure the global minimum tax (GMT) for multinational enterprise groups, a global effort to ensure large corporations pay their fair share of taxes. 

Modifications with the standard 

The form for the Country by Country Report (CbCR) for multinational companies under the scope of this regulation must be submitted as part of the Corporate Income Tax form. The information to be provided in the new Pillar Two form includes several key points. It must be checked whether the group’s turnover reaches €750 million to determine if the company falls within the scope of the Global Minimum Tax (GMT).

Additionally, it is necessary to identify whether the company is the ultimate parent entity of the multinational group or, if not, to indicate which entity is. Another key requirement is to determine if the company will be responsible for submitting the information related to the GloBE (Global Anti-Base Erosion) rules for the fiscal year; if not, the group entity that will do so, as well as its jurisdiction, must be identified. Finally, it must be indicated whether a group company has been designated as responsible for the submission and payment, where applicable, of the domestic minimum tax, along with its identification data. 

Non-compliance and penalties 

In case of delay or non-compliance with these reporting obligations, the French Tax Code provides for fines of up to €100,000. If incomplete declarations or declarations with erroneous data are submitted, the fine could reach €50,000. These penalties underscore the importance of accuracy and compliance within this new regulatory framework. 

International organizations such as the EU and the OECD are increasing their controls over multinationals and investment funds to ensure transparency and tax equity. Therefore, if your multinational or fund has operations in France and needs to ensure efficient management and compliance with local tax regulations, including the new Pillar Two guidelines, our team of experts is at your disposal. 

We invite you to contact us via our form for a personalized consultation on how we can help you with Pillar Two compliance in France and other jurisdictions. 

At Auxadi, we offer comprehensive services in accounting, tax, payroll, and corporate legal services to multinationals and funds. With experience since 1979 and a presence in over 50 countries, including 22 proprietary subsidiaries, our advanced technological platform and proven methodology enable us to guarantee efficient management in compliance with local regulations.