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CMS Expert Guide to Mastering OECD's Pillar Two in France

Key stages in the introduction of global minimum taxation

Table of contents
  1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?
  2.  What is the implementation status of Pillar Two/GloBE rules?
  3.  Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?
  4.  When will the Income Inclusion Rule (IIR) come into force? 
  5.  When will the Undertaxed Payments Rule (UTPR) come into force?  
  6.  Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?
France
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1. Has there been a formal indication of the intention to implement Pillar Two/GloBE rules?

Yes.

2. What is the implementation status of Pillar Two/GloBE rules?

The EU Minimum Taxation Directive was transposed into French domestic law through the Finance Bill for 2024 which was published in the Journal Officiel of 30 December 2023 and came into force.

3. Have the local tax authorities published guidelines commenting on Pillar Two/GloBE rules?

The timetable for publication of the administrative guideliens is not yet known. Guidelines should be probably published in the first half of 2024.

4. When will the Income Inclusion Rule (IIR) come into force? 

Fiscal years beginning after December 31, 2023.

5. When will the Undertaxed Payments Rule (UTPR) come into force?  

Fiscal years beginning after December 31, 2024.

6. Is there any intention to implement a Qualifying Domestic Minimum Top-Up Tax (QDMTT)? If so, when?

Yes
Fiscal years beginning after December 31, 2023.