Global minimum tax 15 % in 2026: concrete reporting obligations for French mid-sized groups with foreign subsidiaries

Updated on 17 September 2025.

Directive EU 2022/2523, transposed into French law by Article 33 of Law no. 2023-1322 of 29 December 2023, imposes a 15 % global minimum tax on multinational enterprise groups and large national groups whose consolidated turnover exceeds €750 million.

Long perceived as a topic reserved for CAC 40 multinationals, this mechanism — commonly referred to as "Pillar 2" in OECD terminology — enters its concrete reporting phase in 2026. On 4 May 2026, the DGFiP opened the production service for the first GloBE Information Return (GIR), with a filing deadline of 30 June 2026 for fiscal years ending on or before 31 December 2024.

For French mid-sized groups (ETI) close to the threshold with foreign subsidiaries, this first campaign is anything but theoretical. This article breaks down the exact scope, the three complementary taxes (INC, IIR, UTPR), the available transitional safe harbours and the operational checklist for the 30 June 2026 filing.

• Threshold: consolidated turnover ≥ €750 M in 2 of the last 4 fiscal years.
• Scope: multinational AND large French national groups.
• Three complementary taxes: INC (French QDMTT), IIR (income inclusion), UTPR (undertaxed profits, from 31/12/2024).
• First GIR filing: due 30 June 2026 for fiscal years closing before 31 December 2024.
• Transitional safe harbours: available 2024–2026 to avoid full GloBE computation.
• Format: XML compliant with DGFiP/OECD schema (guide GU-2259-SD-2026).

The €750 million threshold

The mechanism applies to groups — multinational or large national French — whose consolidated turnover reaches or exceeds €750 million in at least 2 of the last 4 fiscal years preceding the year considered (Article 223 VS-G CGI).

Turnover is assessed based on the ultimate parent entity (UPE)'s consolidated financial statements, prepared in accordance with an accepted accounting standard (IFRS, US GAAP, accepted local GAAP).

Excluded entities

• Government entities, IGOs, sovereign funds (not UPE of a group).
• Eligible non-profit organisations.
• Pension funds.
• Investment funds that are UPEs (but their controlled investments may be).
• Real estate investment vehicles that are UPEs.

Our expert view

The classic €750 M trap: French mid-sized groups near the threshold underestimate their exposure. An ETI at €700 M that acquires €100 M of revenue mechanically crosses the threshold — with a very short runway to put in place the required information systems. The GIR requires granular data (per-jurisdiction ETR, tangible assets, payroll) that does not exist in a standard French accounting set-up without preparation. We recommend that ETIs from €500 M consolidated turnover scope their dispositif as early as 2026, even if they are not in scope this year — the risk of crossing in 2027–2028 is real and implementation takes 12–18 months.

The French Pillar 2 regime combines three coordinated mechanisms of minimum taxation (Articles 223 VS-A et seq. CGI):

National Complementary Tax (INC) — French QDMTT

• Target: gap between 15 % and the effective tax rate (ETR) of French entities of an in-scope group.
• Logic: defensive — preventing another state from collecting the top-up tax.
• Effective: fiscal years opening on or after 31 December 2023.
• Status: France obtained the Qualifying QDMTT OECD status, enabling the QDMTT safe harbour.

Income Inclusion Rule (IIR)

• Target: gap between 15 % and the ETR of foreign subsidiaries of a French-parented group.
• Logic: offensive — France collects the top-up on undertaxed foreign subsidiaries.
• Effective: fiscal years opening on or after 31 December 2023.

Undertaxed Profits Rule (UTPR)

• Target: subsidiary — when the UPE is in a state that does not apply the IIR.
• Effective: fiscal years opening on or after 31 December 2024 (one-year lag).

Summary

The core of the regime is the effective tax rate (ETR) computed per jurisdiction:

ETR jurisdiction = (Adjusted covered taxes) / (Jurisdictional GloBE income)

Covered taxes include corporate income tax, withholding taxes on dividends, equivalent taxes. Excluded: wealth taxes, transfer duties, indirect taxes.

GloBE income starts from local consolidated accounting profit, adjusted for:

• Removing exempted dividend income.
• Reintegrating permanent non-deductible tax expenses.
• Specific treatment of disposal gains on shareholdings.
• Pro-rata allocation of intragroup intangibles.

If a jurisdiction's ETR < 15 %, a top-up tax is due on the excess of GloBE income over the substance-based income exclusion (SBIE):

SBIE = 8 % × tangible asset value + 8 % × payroll (2024), declining to 5 % by 2034

Simplified worked example

French group Alpha: consolidated turnover €900 M, Irish subsidiary (GloBE income = €50 M, covered taxes = €5 M, tangibles = €20 M, payroll = €15 M).

The French parent owes €2.36 M of top-up tax (IIR) on the undertaxed Irish subsidiary.

For fiscal years opening between 2024 and 2026, the OECD and France implemented three simplified safe harbours based on Country-by-Country Report (CbCR) data:

Safe harbour 1 — De minimis test

• Jurisdictional turnover < €10 M AND profit before tax < €1 M.

Safe harbour 2 — Simplified ETR test

• Simplified ETR reaches 15 % in 2024, 16 % in 2025, 17 % in 2026.

Safe harbour 3 — Routine profit test

• Profit before tax ≤ simplified SBIE (8 % payroll + 8 % tangibles in 2024, declining).

How many ETIs can benefit?

In practice, 70 to 80 % of in-scope French ETIs can rely on at least one safe harbour for each of their foreign jurisdictions. The GIR remains required, but it simply records the safe harbour application — without full GloBE computation — for the covered jurisdictions. This is the major operational relief lever for the 2026 campaign.

Before 30 June 2026 (filing deadline)

• Confirm scope: consolidated turnover ≥ €750 M in 2 of 4 last fiscal years.
• Designate the French designated reporting entity (EDD) and notify the DGFiP.
• Collect 2024 CbCR per jurisdiction: turnover, pre-tax profit, paid taxes, tangibles, employees.
• Test safe harbours per jurisdiction.
• Compute full ETR for jurisdictions that fail safe harbours.
• Compute top-up tax (INC + IIR) where applicable.
• Prepare GIR in XML format compliant with DGFiP schema GU-2259-SD-2026.
• File via professional account on impots.gouv.fr before 30 June 2026.
• Settle French top-up tax (payment schedule aligned with filing).

For future years (2025, 2026, 2027)

• Data infrastructure able to aggregate per-jurisdiction data.
• Annual safe harbour review (rates rise each year).
• Group-wide coordination on GloBE adjustments.

• Sanctions: missing GIR filing = €100,000 per missing return (Article 1729 G CGI), plus assessment penalties for omissions.
• CIR/CII coordination: research tax credits can lower a French jurisdiction's ETR — check net impact against the 15 % floor.
• Reinforced transfer pricing: the DGFiP now cross-checks GIR and TP documentation. Material discrepancies trigger audits.
• 2026 implementing decrees: monitor BOFiP-Pillar 2 publications expected end-2026.
• OECD 2026 deadlines: the Inclusive Framework may issue corrective guidance (e.g., the "relevant enterprise profits" regime initially postponed).

The global minimum tax is no longer an academic debate: France's first reporting campaign opened on 4 May 2026 and closes on 30 June. For French mid-sized groups with foreign subsidiaries, the operational challenge is to leverage transitional safe harbours to neutralise full GloBE computation on 70–80 % of jurisdictions, and to target deep analysis on the residual perimeter.

Our firm advises French ETIs on their first Pillar 2 campaign: scoping audit, safe harbour qualification, GIR preparation. Contact our experts to frame your 2026 campaign before the 30 June deadline.