GloBE Country Guide: France

Summary

Status	Enacted Law
Law	On December 5, 2024, Decree No. 2024-1126 was published in the French Official Gazette. This provides additional details on the reporting requirements for Pillar 2 purposes. On 10 October 2024, the French Government presented the draft Finance Bill for 2025 to Parliament. On December 30, 2023, the French Official Gazette published the 2024 Finance Act. This includes provisions to enact the EU Minimum Tax Directive.
Effective Date	Accounting periods beginning on or after December 31, 2023
IIR	Yes (2024)
UTPR	Yes (2025)
QDMTT	Yes (2024)
Filing Deadlines	Standard
Safe Harbours	Transitional CbCR Safe Harbour and the Transitional UTPR Safe Harbour. The QDMTT Safe Harbour and NMCE Simplified Calculations are included in the 2025 Finance Bill.

Legislation
General
Differences to Model Rules
Qualifying Domestic Minimum Top-Up Tax
Administration and Filing
Penalties

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Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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