05 February 2025 France publishes the new declaration form for CbCR and Pillar Two notification
On 27 January 2025, the French tax authorities (FTA) introduced new form No. 2065-INT-SD, which must be submitted as part of corporate income tax (CIT) returns filed by companies that are part of a multinational enterprise (MNE) group subject to country-by-country reporting (CbCR), as well as by entities belonging to an MNE or national group that falls within the scope of the global minimum tax for large groups, introduced by the Finance Bill for 20241 (Pillar Two). The FTA published new form No. 2065-INT-SD on its website impots.gouv.fr. MNE groups subject to CbCR under Article 223 quinquies C of the French Tax Code (FTC), and entities belonging to an MNE or national group that falls within the scope of Pillar Two under FTC Articles 223 VJ and following must submit the form with their annual CIT return. The new form is accompanied by an explanatory notice. The CbCR section of the new form (Section I) reproduces information that was required in section G of tax form No. 2065-SD prior to its 2025 version. The Pillar Two section of the form (Section II) requires reporting the following information with the filing of CIT return related to financial year (FY) ending on or after 31 December 2024:
Regarding the last item (Section II, item 5), the French tax authorities underscore in the instructions to the form that "the box must be checked whether the settlement statement is submitted to pay the top-up tax in its name or on behalf of several constituent entities of the group." The instructions go on to emphasise that "the option provided for in I of Article 1679 decies of the FTC only allows for the centralization of the payment of the tax due under the DMTT and the UTPR. If the constituent entity is liable for a top-up tax under the income inclusion rule (IIR), it must in all cases indicate that it will submit a settlement statement by checking the first box located in paragraph 5 of section II c. If applicable, it must also identify the constituent entity designated to submit the settlement statement centralizing the payment of the top-up tax due under the DMTT and the UTPR." It should be noted that this form takes into account the modifications provided for in the draft Finance Bill for 2025, even though the Bill has not yet been formally approved by the French Parliament. MNEs with interests in France should be prepared to file the new form No. 2065-INT-SD, due by 19 May 2025 for calendar year taxpayers, and consult with their tax advisors as needed.
Document ID: 2025-0401 | ||||||||