| Status | Enacted Law |
| Law | 2027 Finance Bill — government amendment rejected On 10 October 2026, the Government tabled amendment I-3734 to Bill No. 3210. It proposed elective Side-by-Side and UPE safe harbours from financial years beginning on or after 1 January 2026, a one-year Transitional CbCR Safe Harbour extension and related implementation changes. The National Assembly rejected amendment I-3734 on 28 October 2026 at first reading. The measures described here were not adopted through this amendment; its rejection does not change existing French law. Any later replacement or reintroduction must be checked separately. The proposed Side-by-Side relief preserves the French domestic minimum top-up tax. Detailed analysis. On December 3, 2025, France updated its Pillar 2 Guidance to include guidance on: -the procedures for taking into account deferred taxes and assets transferred in respect of the transition year and subsequent years; – the temporary exemption for groups in their initial phase of international activity. On October 14, 2025, France released the 2026 Finance Bill. This includes amendments to include the June 2024 OECD Administrative Guidance, as well as DAC 9 implementation. 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 February 15, 2025, the French Finance Act 2025 was published in the Official Gazette. Article 53 includes amendments to the French Global Minimum Tax Regime for the OECD Administrative Guidance. 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 Act. Rejected proposal: amendment I-3734 of 10 October 2026 proposed adding the Side-by-Side and UPE safe harbours and extending the Transitional CbCR Safe Harbour by one year. The National Assembly rejected I-3734 on 28 October 2026. These changes were not adopted through that amendment; the existing rules remain unchanged. Any replacement text requires separate verification. |
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