Pillar Two: 15% global minimum tax for French groups

Pillar Two: 15% global minimum tax for French groups#

Pillar Two introduces a 15% global minimum tax framework for large multinational groups and large domestic groups. For French finance teams, this is not a narrow tax filing. It affects consolidation, deferred tax, country-by-country data, foreign subsidiaries, ERP reporting and closing governance.

This guide is for French groups, French subsidiaries of foreign groups, holding companies, fast-growing mid-caps, tax teams, CFOs and consolidation teams. It connects with our resources on holding tax planning, French tax consolidation, consolidated accounts, France holding and EU subsidiary structures and multi-country accounting.

French tax guidance states that the top-up tax applies to French entities belonging to a group with consolidated revenue of at least EUR 750 million in at least two of the four preceding fiscal years. The goal is to ensure a minimum effective tax rate of 15% by jurisdiction.

Freshness note: updated on 3 May 2026. Deadlines must be confirmed by fiscal year-end, first in-scope year and current DGFiP instructions.

The key entry threshold is group-level consolidated revenue: at least EUR 750 million in at least two of the previous four fiscal years. The French rules can apply to groups with French entities even where the French subsidiary itself is much smaller.

This is the first trap for French subsidiaries of foreign groups. Local finance may not own the group consolidation data, yet French compliance obligations can still arise locally.

Pillar Two checks whether a group is sufficiently taxed in each jurisdiction. If the GloBE effective tax rate in a jurisdiction is below 15%, a top-up tax may be due. The calculation uses its own concepts: qualifying income, covered taxes, deferred tax adjustments, exclusions and transitional safe harbours.

Our chartered accountant view: Pillar Two is where tax and consolidation meet. Treating it as a year-end tax adjustment is too late if the source data is not auditable.

French guidance states that, in principle, each French entity in an in-scope group must file an information return, unless a valid designation mechanism applies. Where top-up tax is due in France, a liquidation return and electronic payment may also be required.

For fiscal years ending 31 December 2024, the French declarative path points to a first-cycle deadline of 30 June 2026 for the GloBE information return and payment return. Later cycles generally move to a 15-month timeline, subject to applicable rules.

GloBE computations require data that may not sit in the French statutory ledger: covered taxes, adjusted deferred taxes, consolidation adjustments, entity classifications, permanent establishments and local tax credits. A French subsidiary can be responsible for compliance while depending on group data it does not control.

Reporting tools such as Power BI can support monitoring, but they do not replace tax qualification. Groups with multiple French entities should also review our consolidation accountant page.

Management must settle three questions: ownership, data and calendar. Who owns Pillar Two? Which systems produce the data? What external review is needed before filing?

1. Confirm group-level scope.
2. Identify French entities and local obligations.
3. Decide whether a single entity can file or pay for the group.
4. Build a data-production calendar aligned with close.
5. Document sensitive tax judgements before filing.

Hayot Expertise supports groups through French corporate tax services, holding tax advice and French accounting services.

• The first filing cycle creates pressure for calendar-year groups.
• French subsidiaries need evidence of group-level designations.
• Top-up tax is separate from corporate income tax.
• Tax credits and local incentives need GloBE qualification, not only French accounting treatment.
• Scope errors are often more damaging than calculation errors.