At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-09-30. Tax authority: Direction générale des Finances publiques (DGFiP). Summaries are simplified; check the linked official source before relying on them.
The law
#Article 57 of the Code général des impôts (CGI) adds back profits shifted abroad to related parties. Documentation and filing rules are in Article L13 AA and L13 B of the Livre des procédures fiscales (LPF) and Articles 223 quinquies B and C CGI. The administration follows the OECD Guidelines (BOFiP BOI-BIC-BASE-80).
Documentation
#Companies with turnover or gross assets of at least EUR 150m (or that hold, or are held more than 50% by, such an entity, or belong to a French tax group with such an entity) must keep a master file and a local file (L13 AA LPF). The EUR 150m threshold applies to fiscal years opened from 1 Jan 2024 (it was EUR 400m). The file must be available on the day a tax audit starts. If it is missing or incomplete, the tax office sends a formal notice giving 30 days (extendable to 2 months in total). Documentation should in principle be in French, and translations can be requested. Smaller companies have no fixed documentation duty, but in an audit the tax office can request TP information under L13 B LPF with at least 2 months to reply (up to 3 months on request). Separately, companies with turnover or gross assets of at least EUR 50m (and related group members) must file the annual TP return 2257-SD.
Methods
#OECD methods are accepted. No strict hierarchy in law; the administration follows the OECD most appropriate method approach. Since 2024 the documentation can be used against the company if actual practice differs from what it describes.
Penalties
#Failure to provide L13 AA documentation after formal notice: fine of the higher of 0.5% of the undocumented transactions or 5% of the related Article 57 reassessment, minimum EUR 50,000 per audited year (Art. 1735 ter CGI, minimum raised from EUR 10,000 by the 2024 Finance Law). Missing or late 2257-SD: EUR 150, and errors or omissions EUR 15 each (min EUR 60, max EUR 10,000) under Art. 1729 B CGI. Normal tax reassessment penalties also apply.
Pillar Two
#France applies the IIR and a QDMTT to fiscal years starting on or after 31 December 2023 and the UTPR from 31 December 2024. Each French entity notifies with its CIT return (form 2065-INT-SD), then the GIR (2259-SD) and the payment statement (2272-SD) with payment are due 15 months after year end, 18 months for the first year. The first 2024 campaign was extended from 30 June to 1 September 2026.
Other rules
#Unilateral and bilateral APAs are available (L80 B 7° LPF). Transfers under Article 57 can be treated as deemed distributions, which may trigger withholding tax (a secondary effect). Interest deduction is limited to the higher of 30% of tax EBITDA or EUR 3m (Art. 212 bis CGI), plus an arm's length interest rate test for related-party loans (Art. 212 I CGI).
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Corporate income tax return (liasse 2065-SD) Due within 3 months after the fiscal year end. Exception: if the fiscal year ends on 31 December, the deadline is the second business day after 1 May of the next year. Companies that file online get an extra 15 days, so in practice December year ends file in mid to late May. | Extended: online filing, 15 extra days (e.g. May 20, 2026); original due date May 5, 2026 | All companies subject to corporate income tax. | impots.gouv.fr: Imposition des résultats |
| 2 | CbC notification (form 2065-INT-SD, section I) Filed as an annex to the corporate income tax return. The entity says whether it is the parent, the designated filer, or neither, and if neither, names the group entity that files the CbC report and its country. Section II of the same form covers Pillar Two. | With Corporate income tax return (liasse 2065-SD) (extended) (e.g. May 20, 2026); original due date May 5, 2026 | French entities of a multinational group in which an entity must file a CbC report (group revenue of at least EUR 750m). | Form 2065-INT-SD (2026) and notice |
| 3 | Pillar Two notification (form 2065-INT-SD) Each French entity of an in-scope group files this notification with its corporate income tax return each year. It names the parent, where the GIR will be filed, and the designated GIR and payment filers. It gives access to the GIR and payment services. | With Corporate income tax return (liasse 2065-SD) (extended) (e.g. May 20, 2026); original due date May 5, 2026 | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | impots.gouv.fr: Global minimum tax reporting and compliance process |
| 4 | Annual TP return (form 2257-SD) Filed online within 6 months after the corporate income tax return deadline (Art. 223 quinquies B CGI). For a non-December year end that is 9 months after year end. For a 31 December year end the CIT deadline falls in early May, so the 2257-SD is due in early November of the next year. Gross assets also count toward the EUR 50m test. | 6 months after the return deadline (e.g. Nov 5, 2026) | French companies with turnover or gross assets of at least EUR 50m, or that hold, or are held more than 50% by, such an entity, or that belong to a French tax group with such an entity. | BOFiP BOI-BIC-BASE-80-10-30 (2257-SD) |
| 5 | Country-by-country report (form 2258-SD) Filed online within 12 months after the end of the fiscal year (Art. 223 quinquies C CGI). | 12 months after year end (e.g. Dec 31, 2026) | French parent of a group with consolidated revenue of at least EUR 750m, or a French entity that must file locally. | Article 223 quinquies C CGI (Légifrance) |
| 6 | GloBE Information Return (form 2259-SD) Filed in XML 15 months after year end, 18 months for the first year (30 June 2026 for calendar 2024). Not needed locally if filed centrally in a country with an exchange agreement. The first campaign was extended to 1 September 2026 (impots.gouv.fr notice: https://www.impots.gouv.fr/actualite/la-campagne-de-collecte-des-declarations-gir-imprimes-2259-sd-est-prolongee-jusquau-1er). Penalty: EUR 100,000 per missing or late return, capped at EUR 1m per year for the group. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | impots.gouv.fr: Global minimum tax reporting and compliance process |
| 7 | Top-up tax payment statement (form 2272-SD) and payment Notice of payment and top-up tax payment are due on the same date as the GIR. Covers IIR, UTPR and the French QDMTT. IIR and QDMTT apply to fiscal years starting on or after 31 December 2023; the UTPR from 31 December 2024. | 15 months after year end (e.g. Mar 31, 2027) | Groups with consolidated revenue of at least EUR 750m in at least two of the four preceding fiscal years. | impots.gouv.fr: Global minimum tax reporting and compliance process |
| 8 | Master file (fichier principal) Must be available on the date a tax audit starts. If it is missing or incomplete, the tax office sends a formal notice giving 30 days to provide it, extendable to 2 months in total. Gross assets also count toward the EUR 150m test. | Within 30 days of a tax authority request | French companies with turnover or gross assets of at least EUR 150m, or linked to such an entity by more than 50% ownership, or in a French tax group with such an entity (fiscal years opened from 1 Jan 2024). | BOFiP BOI-BIC-BASE-80-10-40 (L13 AA documentation) |
| 9 | Local file (fichier local) Must be available on the date a tax audit starts. A 30-day formal notice applies if it is missing or incomplete. Transactions above EUR 100,000 per type must be described. Companies below the threshold can still be asked for TP information in an audit under L13 B LPF, with at least 2 months to reply (up to 3 months on request). | Within 30 days of a tax authority request | Same scope as the master file (EUR 150m turnover or gross assets, or linked entities). | BOFiP BOI-BIC-BASE-80-10-40 (L13 AA documentation) |
Official texts
#- Code général des impôts and Livre des procédures fiscales (Légifrance) (Licence Ouverte / Open Licence 2.0 (Etalab) for DILA legal data; attribution and date of last update required)
- BOFiP-Impôts (official tax doctrine) (Believed to be Licence Ouverte 2.0 (published as open data); confirm before reuse)