France: Additional Pillar Two guidance
Clarifying transition aspects and deferred tax treatment under Pillar Two rules
The French tax authorities on December 3, 2025, issued new guidance providing clarifications and examples on the transition aspects of the Pillar Two rules in France.
The guidance includes clarifications on the treatment of pre-regime deferred tax attributes, the type of deferred tax attributes not allowed to transition into the Pillar Two regime, and the treatment of intra-group asset transfers before the application of the global anti-base erosion (GloBE) rules. It also addresses the application of the exclusion for the initial phase of international activity.
Additional guidance focusing on safe harbour rules, effective tax rate calculation, top-up tax liability, charging mechanisms, and filing and payment is being drafted.
Read a December 2025 report prepared by KPMG’s EU Tax Centre