05 February 2025

France publishes the new declaration form for CbCR and Pillar Two notification

  • The new declaration form is part of the standard corporate income tax return for 2024, due by 19 May 2025 for calendar year taxpayers.
  • It must be filed by companies that are part of a multinational group subject to country-by-country reporting and/or by entities belonging to a multinational or national group that falls within the scope of the global minimum tax for large groups (Pillar Two).
 

Executive summary

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).

Detailed discussion

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:

  • Whether the company is within the scope of the global minimum tax for large groups (Section II, item 1)
  • Whether it constitutes the ultimate parent entity (UPE) or is another constituent entity (Section II, item 2); in the latter case, it must provide the identity of the UPE
  • Whether the company will submit,2 for the relevant FY, the information return for the top-up tax or, if not, indicate the constituent entity designated to do so and in which country it is located (Section II, item 3)
  • Whether the company is the constituent entity designated by the group as liable for the domestic minimum top-up tax (DMTT) due to the under-taxation of investment entities and insurance investment entities (under paragraph 4 of IV of FTC Article 223 WF), in which case it must also indicate the name and contact details of the concerned entities in France (Section II, item 4)
  • Whether the company will submit,3 for the relevant FY, the settlement statement of the top-up tax, specifying, if applicable, which entity the group designated to submit the settlement statement in France for the tax resulting from the DMTT or the undertaxed profit rule (UTPR) (if the option provided for in FTC Article 1679 decies is exercised) (Section II, item 5).

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.

Implications

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.

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Endnotes

1 See EY Global Tax Alert, French Parliament approves Finance Bill for 2024, including OECD Pillar Two rules, dated 22 December 2023.

2 Note that for the first FY for which the group is subject to Pillar Two, the company must submit the information return and settlement statement within 18 months of the end of the FY, which means by 30 June 2026 for the FY ending on 31 December 2024.

3 Id.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young Société d'Avocats, Paris

Ernst & Young LLP (United States), French Tax Desk, New York

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2025-0401