France: Form for Pillar Two reporting requirements, country-by-country notification

Pillar Two reporting requirements added to CbC notification form

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January 27, 2025

Following the release on December 5, 2024, of the decree on Pillar Two filing and notification obligations (read TaxNewsFlash), the French tax authorities on January 24, 2025, released the new form to be used to fulfil the reporting obligations for entities within the scope of the French Pillar Two law.

As expected, the form requires information such as the name, address, and tax number of the ultimate parent entity (UPE), the entity responsible for filing the group information return (GIR) if different, and the French entity responsible for filing the qualified domestic minimum top-up tax (QDMTT) and paying any additional top-up tax, if applicable. A specific section also requests information on the paying entity (designated by the group) for the domestic minimum top-up tax (DMTT) due by French investment entities.

The first section of this form also serves as a notification form for the country-by-country (CbC) reporting obligations, which were previously included in Form 2065-SD until last year.

The form must be filed along with the corporate income tax (CIT) return, adhering to the same deadline: three months after the end of the fiscal year or by May 19 for the fiscal year ending December 31, 2024, if the CIT return is filed electronically.

For more information, contact a KPMG professional at KPMG Avocats:

Laurence Mazevet | laurencemazevet@kpmgavocats.fr

Marie-Pierre Hoo | mhoo@kpmgavocats.fr

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