France: No implementation of Pillar One Amount B, but acceptance of Amount B outcomes in covered jurisdictions

Applicable for fiscal years beginning January 1, 2025

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OCTOBER 27, 2025

The tax authority announced that France will not apply Amount B under Pillar One domestically for fiscal years beginning January 1, 2025, but will accept its application in covered jurisdictions with tax treaties with France, committing to eliminate double taxation.

Covered jurisdictions are generally low- and middle-income Inclusive Framework jurisdictions, excluding EU, OECD, and G20 members unless they meet specific criteria.
 

For further information, contact a KPMG tax professional in France:

Marie-Pierre Hôo | mhoo@kpmgavocats.fr

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