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| Status | Enacted Law |
| Law | 2027 Finance Bill — government amendment (proposal) On 10 October 2026, the Government tabled amendment I-3734 to Bill No. 3210. It proposes 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 Assembly records it as under processing, subject to admissibility; it is not adopted or enacted. 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. Proposed, not enacted: amendment I-3734 of 10 October 2026 would add the Side-by-Side and UPE safe harbours and extend the Transitional CbCR Safe Harbour by one year. Eligibility would depend on the relevant elections and qualification requirements; the proposal does not itself change the existing rules. |
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