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PILLAR TWO / GLOBE

Pillar Two (GloBE): scoping, calculations and GIR filing

Pillar Two, or the GloBE rules, introduces a 15% minimum effective tax rate per jurisdiction for groups with consolidated revenue of €750 million or more. We support in-scope groups and their French subsidiaries, from scoping through to filing the GloBE Information Return (GIR).

15% minimum tax per jurisdiction In jurisdictions taxed below 15%, a top-up tax is due, collected in this order: domestic tax, income inclusion rule, then undertaxed profits rule. Top-up tax 15% minimumrate JurisdictionAJurisdictionBJurisdictionCJurisdictionDJurisdictionEJurisdictionF 1. Domestic minimum top-uptax 2. Income inclusion rule 3. Undertaxed profits rule 15% minimum tax per jurisdiction In jurisdictions taxed below 15%, a top-up tax is due, collected in this order: domestic tax, income inclusion rule, then undertaxed profits rule. Top-up tax 15% minimum rate Jurisdiction AJurisdiction BJurisdiction CJurisdiction DJurisdiction EJurisdiction F 1. Domestic minimum top-up tax 2. Income inclusion rule 3. Undertaxed profits rule
In jurisdictions taxed below 15%, a top-up tax is due, collected in this order: domestic tax, income inclusion rule, then undertaxed profits rule.

What the engagement covers

Implementing Pillar Two draws on accounting, tax and consolidation data at the same time. We cover the whole chain: identifying constituent entities, testing safe harbours, calculating the effective tax rate per jurisdiction and any top-up tax, then preparing the returns. Where the group operates in several countries, we coordinate with local advisers. Each step is documented to make the following years easier.

  • Scoping and mapping of constituent entities
  • Testing of the safe harbours based on country-by-country reporting
  • Calculation of the GloBE effective tax rate per jurisdiction
  • Top-up tax: qualified domestic minimum top-up tax, income inclusion rule, undertaxed profits rule
  • Preparation and filing of the GloBE Information Return and related French returns
  • Coordination with local advisers and documentation of positions taken

Who it is for, and when

French groups with consolidated revenue above the €750m threshold; French subsidiaries of international groups subject to the GloBE rules, which must provide data or file returns in France; tax and finance teams preparing a first return or wanting to secure a process set up in a hurry. We also provide technical support to accounting firms on Pillar Two files.

How we work

  1. Scoping: group perimeter, jurisdictions, available data, filing calendar.

  2. Safe harbours: tests by jurisdiction and documentation.

  3. GloBE calculations for jurisdictions without a safe harbour.

  4. Returns: preparation of the GIR and the French returns.

  5. Filing and follow-up: tax authority feedback and documentation for the following year.

FAQ

Is my group within the scope of Pillar Two?

The rules apply to groups with consolidated revenue of at least €750m in at least two of the four preceding financial years. A mid-sized company owned by a foreign group subject to the rules may also be affected: its French companies are then constituent entities of that group and have their own obligations in France.

When is the GIR due?

The return is generally due within 15 months of the financial year end. For the first year in scope, the deadline is extended to 18 months. For a financial year ended 31 December 2024, the first deadline was therefore 30 June 2026.

What is a safe harbour?

A safe harbour exempts the group from detailed GloBE calculations in a jurisdiction when certain conditions are met. The transitional safe harbours are based on country-by-country reporting: de minimis, simplified effective tax rate or routine profits test. They must be tested and documented jurisdiction by jurisdiction, every year.

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