Pillar 2 | Registration before May 17, 2025

As a reminder, Pillar 2 aimed at ensuring a minimum level of global taxation for multinational enterprise groups with a turnover exceeding 750 million euros, enacted in France for any fiscal year starting on or after January 1, 2024.

In this context, the concerned entities are subject to a number of reporting obligations. The next obligation will occur when filing their tax return for the fiscal year ending December 31, 2024, to be submitted by May 17, 2025.

This notification also applies to French subsidiaries of foreign groups (whether or not the headquarters is located in a country that has introduced a Pillar 2 regime).

More specifically, these entities are required to indicate to the French tax administration, as an annex to their tax return for each fiscal year of application of Pillar 2:

• their membership in such a group,
• the identity of the ultimate parent entity of the group as well as the state or territory in which it is located, its tax identification number, its SIREN number, and its fiscal year start and end dates,
• the identity of the entity filing the group's GloBE information return as well as the state or territory in which it is located, its tax identification number, and its SIREN number,
• the identity of the French entity filing the statement of liquidation of the income inclusion rule, the domestic minimum tax, and the undertaxed payments rule, as well as its address and SIREN number.

In practice, determining certain information can sometimes be complex due to the nature of the applicable rules. For any questions or assistance, a specialized team is at your disposal