France has extended the deadline for filing the first GloBE Information Return (GIR) for fiscal year 2024 to 1 September 2026, following an announcement by the DGFiP on 8 July 2026. This extension affects multinational groups with consolidated revenue of EUR 750 million or more that are subject to the Pillar Two minimum tax framework under EU Directive 2022/2523. International companies with a French constituent entity or a French ultimate parent entity should review their filing obligations immediately in light of this revised deadline and recent OECD guidance.
What Changed and When
The Pillar Two rules, established under the Minimum Tax Directive (EU) 2022/2523, require in-scope groups to file a GloBE Information Return covering their global structure, effective tax rates, and top-up tax positions. For fiscal year 2024, most jurisdictions set an initial GIR filing deadline of 30 June 2026. France's tax authority, the Direction Générale des Finances Publiques (DGFiP), announced on 8 July 2026 that this deadline is extended to 1 September 2026 for groups filing in France.
This development sits within a broader pattern of coordinated extensions across the EU and beyond. Portugal issued Order 76/2026-XXV on 3 June 2026, providing relief from penalties for GIR filings submitted by 30 September 2026. Belgium similarly extended its GIR notification deadline to 30 September 2026. These national measures reflect the practical complexity of first-cycle compliance and the need for alignment with evolving international guidance.
Separately, the OECD/G20 Inclusive Framework approved the Side-by-Side package on 5 January 2026, introducing simplifications, UPE safe harbours, and revised treatment of substance-based incentives. The European Commission confirmed the application of this package under the Directive through Notice C/2026/253 published on 12 January 2026. On 11 September 2026, the OECD released an updated GIR form applicable to fiscal years beginning on or after 31 December 2025, which groups must take into account for subsequent reporting cycles.
Who Is Affected in France
The obligation applies to multinational enterprise (MNE) groups whose consolidated annual revenue meets or exceeds EUR 750 million in at least two of the four preceding fiscal years, in line with the threshold set by Directive 2022/2523. In practice, this captures large groups with a French ultimate parent entity (UPE), as well as groups headquartered elsewhere that have a designated filing entity or constituent entity in France.
Key categories of affected entities include:
- French UPEs with subsidiaries or permanent establishments in other jurisdictions subject to Pillar Two rules;
- Intermediate parent entities or designated local entities in France that have been appointed to file on behalf of the group;
- Foreign-parented groups with significant French operations, where a local filing or notification obligation may arise under French implementation rules;
- Groups that benefit from, or are assessing eligibility for, the transitional safe harbours or the newly introduced Side-by-Side safe harbours.
Groups that have relied on substance-based income exclusions or that operate investment structures should pay particular attention to the updated treatment of substance-based incentives introduced under the Side-by-Side package, as this may affect their effective tax rate calculations and top-up tax positions for FY2024.
Interaction With Broader Tax Risk Management
The GIR filing is not a standalone exercise. It intersects directly with transfer pricing documentation, country-by-country reporting, and existing anti-avoidance rules applicable in France. Groups that have not yet aligned their intercompany arrangements and tax structuring with Pillar Two outcomes risk creating inconsistencies across reporting obligations – inconsistencies that may invite scrutiny during a tax audit by the DGFiP.
The GIR data will be exchanged automatically between competent authorities under the relevant international frameworks, meaning that discrepancies between the GIR and existing transfer pricing or tax treaty positions will be visible to multiple administrations simultaneously. Sound tax risk management therefore requires an integrated approach: reviewing the GIR alongside transfer pricing files, existing advance pricing agreements, and any positions taken under applicable tax treaties.
For groups with cross-border structures involving Norway or other jurisdictions that have published Pillar Two implementation guidance, it is also worth considering how the Side-by-Side package affects your overall group position. Our analysis of the Norway Pillar Two Side-by-Side draft sets out how these simplifications operate in a comparable jurisdiction.
If you have questions about how the French extension affects your group's obligations or wish to discuss your overall Pillar Two exposure, please contact us at info@ferrazwhitmore.com or visit our contacts page.
Immediate Action Items for International Companies
Given the revised deadline and the evolving guidance, we recommend that in-scope groups consider the following steps without delay:
- Confirm your filing entity for France. Establish whether the French entity is the designated filer, a local filing entity, or is relying on a GIR filed by the UPE in another jurisdiction, and ensure that the DGFiP has been notified accordingly.
- Assess the impact of the Side-by-Side package. Review whether the UPE safe harbour or other simplifications introduced under the 5 January 2026 OECD package apply to your group, and ensure that your GIR reflects the Commission's confirmation in Notice C/2026/253.
- Review the updated GIR template. The OECD's updated GIR form, released on 11 September 2026, applies to fiscal years beginning on or after 31 December 2025. While FY2024 filings use the earlier form, groups should understand the forthcoming changes to prepare internal processes for the next cycle.
- Align GIR data with existing documentation. Cross-reference the GIR with transfer pricing files, country-by-country reports, and tax treaty positions to identify and address any inconsistencies before the 1 September 2026 deadline.
- Map obligations in other jurisdictions. If your group has constituent entities in Portugal or Belgium, note that different extended deadlines apply in those countries (30 September 2026 in each case) and coordinate filings accordingly.
Our team advises on tax structuring in France and can assist with the preparation and review of GIR filings, safe harbour assessments, and the alignment of Pillar Two positions with existing transfer pricing and anti-avoidance frameworks.
Looking Ahead
The 1 September 2026 deadline for France is firm on the basis of current guidance. Groups that have not yet commenced their GIR preparation face a compressed timeline. Beyond FY2024, the updated GIR template and the continuing development of the Side-by-Side package signal that compliance requirements will continue to evolve, and that internal processes built for this first cycle will need to be revisited.
The DGFiP has signalled active engagement with Pillar Two compliance, and the exchange of GIR data across jurisdictions means that inconsistent positions are unlikely to go unnoticed. Proactive engagement with corporate and regulatory matters in France remains the most effective form of tax risk management in this environment.
To discuss your group's specific situation in France or across multiple jurisdictions, reach out to our team at info@ferrazwhitmore.com or through our contacts page. We are available to assist with compliance planning, documentation review, and coordination with local advisers.
Sources
- Irish Revenue – Pillar Two key dates: https://www.revenue.ie/en/companies-and-charities/pillar-two/dates/index.aspx
Facts last verified: 22 September 2026.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.