For a foreign-owned group with a French subsidiary, 1 September 2026 is a practical deadline with a narrow but important scope. It is not a new filing date for every company incorporated in France. It is the end of a one-off extension announced for the first French information-return campaign under Pillar 2, the international minimum-tax framework. The first question is therefore not simply whether a French company has a foreign shareholder. It is whether the group is within the EUR 750 million consolidated-revenue threshold and whether the French entity is a constituent entity or a French permanent establishment of that group.

The distinction matters because an ordinary French SAS or SARL may have modest local revenue while still being part of a multinational group whose consolidated accounts trigger the rules. Conversely, a small independent company with overseas customers is not automatically caught. The group must then map its filing role: notification, Global anti-Base Erosion Information Return (GIR), and, where French top-up tax is due, the liquidation statement and payment. A parent company may centralise the GIR abroad, but that does not erase every French notification or local payment obligation.

This guide gives a foreign founder, group tax director and French finance team a decision path for 1 September 2026. It explains the threshold, the French entity test, the documents to assemble, the difference between the GIR and the payment return, central filing, and the response to a missed or technically rejected filing. It does not treat the deadline as proof that tax is owed: filing information and owing top-up tax are separate questions.

For the broader steps involved in establishing and operating a French company, see the firm’s French company formation and corporate structuring hub. This article addresses the narrower Pillar 2 reporting question that arises once a foreign-owned group has a French presence.

I. Does a foreign-owned French company fall within Pillar 2?

A. Is the EUR 750 million threshold and foreign-parent test met?

Pillar 2 is the common name for the OECD/G20 Global anti-Base Erosion (GloBE) rules implemented in France. In practical terms, the rules seek to ensure a minimum effective level of taxation for large groups in each relevant jurisdiction. The French tax code uses its own vocabulary. The Global anti-Base Erosion Information Return is the GIR. A constituent entity is an entity belonging to the group that is not excluded by the statute. The ultimate parent entity is the group entity at the top of the consolidated reporting chain. The domestic minimum top-up tax is often abbreviated DMTT or INC in French materials; “INC” refers to impôt national complémentaire, the French domestic top-up tax. The income inclusion rule is commonly called the IIR or RIR, and the undertaxed profits rule is called the UTPR or RBII.

The starting point is Article 223 VL of the French General Tax Code (Code général des impôts, or CGI). It does not ask whether the French subsidiary alone has EUR 750 million of turnover. It looks to the consolidated financial statements of the ultimate parent and to the group’s revenue over the relevant preceding years. The statutory threshold is expressed as revenue “égal ou supérieur à 750 millions d’euros au cours d’au moins deux des quatre exercices précédant l’exercice considéré” in the wording of Article 223 VL CGI on Légifrance. In English, the practical test is at least EUR 750 million in consolidated revenue in at least two of the four financial years preceding the year under review.

That test eliminates a common mistake made by foreign founders. A French subsidiary with EUR 2 million of local sales may still sit inside the scope if its ultimate parent’s consolidated accounts satisfy the threshold. The converse is also important: a French company that sells internationally, but is not part of a qualifying group, does not enter Pillar 2 merely because its customers or shareholders are abroad. The group perimeter, not the nationality of a founder, determines the first threshold question.

Article 223 VL must be read with Article 223 VK, which defines the multinational group concept. The official definition includes a group with at least one entity or permanent establishment outside the state or territory of the ultimate parent. The Article 223 VK CGI text is therefore relevant where a foreign parent owns a French company, where a French parent owns a foreign subsidiary, or where the group operates through a permanent establishment. The fact that the foreign shareholder is a corporation, investment vehicle or family holding company is not, by itself, the answer. The legal and accounting group perimeter must be established first.

The second mapping exercise is territorial. Article 223 VM of the CGI sets out when an entity is regarded as situated in a state for this chapter. Its rule refers to the place where the entity is subject to tax because of “son siège de direction, de son lieu de création ou d’autres critères similaires”. The Article 223 VM CGI text matters for a French subsidiary, a branch and a permanent establishment because the same group may have several reporting locations and several potential taxing rights.

For a French subsidiary, the practical conclusion is usually straightforward: a company registered and subject to French corporate tax is a French constituent entity if it belongs to the qualifying group and is not excluded. A French branch of a foreign company requires a more careful functional and tax analysis. A permanent establishment is not simply a line in a group chart; its existence and location need to be supported by the underlying tax and accounting records. If the group has an investment structure, joint venture, insurance entity, pension entity or government body, the exclusion rules also need to be checked rather than assumed.

The threshold analysis should be performed from the ultimate parent’s consolidated accounts, not from the French company’s statutory accounts alone. The team should preserve the consolidation perimeter, the four-year revenue bridge, the currency conversion method, the relevant fiscal-year dates and any acquisition or demerger adjustment. If the parent changed its financial year, the “first year” rules and the applicable deadline may differ from an ordinary 12-month calendar year. The French entity should know which group company has authority to make that determination and which source document supports it.

Article 223 VJ supplies the legal consequence once the group is within scope. It states that qualifying multinational and domestic groups are subject to an annual minimum tax. The opening sentence is concise: “Les groupes d’entreprises multinationales et les groupes nationaux mentionnés à l’article 223 VL sont soumis à une imposition minimale annuelle.” The Article 223 VJ CGI text then describes the top-up tax mechanisms and confirms that the top-up tax is not deductible from the corporate income-tax base. This is why the filing team must keep separate the scope test, the jurisdictional effective-tax-rate computation and the payment calculation.

A French operating company may therefore be in scope without immediately having a French payment. A safe harbour, a sufficient effective tax rate, covered taxes, losses, substance-based exclusions or another computation may eliminate or reduce the top-up tax. That result does not necessarily eliminate the information filing. The GIR exists to provide the jurisdictional and group information needed to test the rules, while the liquidation statement records the amount payable where a French top-up tax is due.

The first decision memo for a foreign-owned French company should answer six questions in plain language:

1. Which legal entity is the ultimate parent for the relevant year?
2. Did consolidated group revenue reach at least EUR 750 million in at least two of the previous four years?
3. Is the French company, branch or permanent establishment inside the group perimeter?
4. Is it an excluded entity, or does an exclusion need to be documented?
5. Which entity is designated to file the GIR, and in which jurisdiction?
6. Is a French top-up tax payment expected, possible, or not due on the current computation?

If these answers cannot be given from a single group chart and a signed tax memo, the 1 September file should be treated as a governance issue rather than as a routine form completion.

B. What must the French subsidiary verify before filing?

The French entity should first determine its legal role. Article 223 WF of the CGI addresses the French national top-up tax. The Article 223 WF CGI text should be reviewed where the French jurisdiction has a domestic top-up amount. The entity that is liable for the French amount is not always the same entity that prepares the central GIR. The responsibility can depend on the group designation and on whether the French rule applies to the entity, the ultimate parent or another designated constituent entity.

Next, identify the French tax identifiers and the reporting access. A French company normally has a SIREN or SIRET identifier and a tax account through which its corporate tax filings are managed. The group should check the tax administration’s instructions for an entity that cannot use the ordinary account, especially where the relevant filer is outside France. It should also ensure that the person who will transmit the XML file has the right mandate, that the file can be signed or authenticated, and that the confirmation can be downloaded and retained.

The notification layer deserves separate attention. The French process asks an entity in scope to notify the administration of its group membership and the identity of the ultimate parent. Do not treat this notification as a substitute for the GIR. It serves a different function: it tells the French administration that the entity belongs to the relevant group and identifies the reporting architecture. Article 223 WW of the CGI expressly refers to an electronically filed information return “sous forme dématérialisée, dans un délai de quinze mois”. The Article 223 WW CGI text should be read for the notification, GIR and liquidation-return duties together.

The group should also check the law applicable to the first year of the French Pillar 2 rules. The ordinary statutory period is generally fifteen months after the end of the relevant fiscal year, extended to eighteen months for the first year of application. For a group whose first relevant year ended on 31 December 2024, that first-year period would ordinarily point to 30 June 2026. The Ministry of Finance announced a one-off extension for the GIR campaign to 1 September 2026. The official Ministry announcement records the extension and explains that the first campaign has involved group-data collection, software readiness and technical anomalies.

The extension should not be misread in either direction. It does not turn every French business into a Pillar 2 filer, and it does not create a permanent 1 September deadline for every future year. It gives qualifying groups additional time for the first campaign. The group’s own year-end and the applicable statutory period remain relevant for later years. The tax team should store the Ministry notice with the filing evidence so that a future reviewer understands why a 30 June date was not used for the first campaign.

The computation file should distinguish accounting data from legal conclusions. A GIR may require the group’s consolidated revenue, constituent entities, permanent establishments, jurisdictional income, covered taxes, effective tax-rate information, top-up tax allocations and other group data. It is not enough to send a local trial balance. The French finance team should receive the relevant extracts from the group’s consolidation system, the intercompany eliminations policy, the tax provision, deferred-tax analysis and the allocation of any domestic top-up amount.

The French tax rules also contain transitional safe harbours. Article 223 VZ bis describes a transitional minimum-tax-rate test for the relevant years. One part of the provision fixes rates by opening year, including “17 % pour les exercices ouverts du 1er janvier au 31 décembre 2026”. The Article 223 VZ bis CGI text must be applied as a safe-harbour provision, not as a statement that every French company pays 17 percent. A group that believes it qualifies for a safe harbour should preserve the calculations and the source data supporting the election or conclusion.

The implementing decree is also part of the file. Decree No. 2024-1126 of 4 December 2024 sets out the implementing provisions for the reporting obligations, including the relevant provisions of Annex III to the CGI. It is useful when the group’s software team asks what the XML payload must contain or when a central filer asks which French entity must notify the administration. The tax director should not approve a file merely because the software accepts it; the file must match the legal entity map and the designated-filer decision.

Before the deadline, the French entity should assemble a controlled evidence pack containing the group chart; ultimate-parent identification; consolidated revenue test; fiscal-year dates; French entity identifiers; exclusion analysis; designation or central-filing evidence; XML validation report; notification confirmation; GIR transmission receipt; payment computation or no-payment analysis; and the internal approval record. Keep the file in English if that is the group’s working language, but preserve the French form names and the French legal references so the file can be understood by the French administration or a French adviser.

II. What must the group file by 1 September 2026, and what if it misses the date?

A. Which notification, GIR and payment filings are required?

The three filing layers should be mapped before anyone opens the software. First is the notification of group membership and the identity of the ultimate parent. Second is the GIR, the information return used to communicate the Pillar 2 data. Third is the liquidation statement and payment where French top-up tax is due. Treating the three layers as one “Pillar 2 form” is a frequent source of omissions, especially when the ultimate parent has appointed a central filer outside France.

The French tax administration’s summary of the three reporting obligations explains that entities within scope must address the notification, the GIR and the payment or liquidation notice. The same official page describes the GIR as an electronic filing generally due within fifteen months after the fiscal year, or eighteen months for the first year of application. It also explains that a designated entity may make the central filing where the statutory conditions are met. The group should use that page together with the current form instructions, because a translated group checklist may not reflect the French filing labels.

The GIR is not a narrative letter. The tax administration expects a structured electronic return. The DGFiP page on filing the GIR and liquidation statement identifies the 2259-SD information return, the XML format and the separate liquidation statement. The group’s software should be tested against the official schema and user guide. A PDF printout may help internal review, but it is not a replacement for the accepted electronic transmission.

For the first campaign, the official Ministry notice states that the initial global deadline was 30 June 2026 for fiscal years ending on 31 December 2024 and that the French campaign was extended to 1 September 2026. The date is therefore decisive for a group that falls within the first campaign and has not yet filed. It is not a reason to submit a form for a French subsidiary that fails the group-threshold test. The responsible tax director should record the exact year-end, the statutory due date, the extension relied upon and the time zone used by the filing platform.

Central filing is possible only after the designation and exchange conditions have been verified. Article 223 WW bis of the CGI addresses an entity that is relieved from the French information filing where the required information is filed by the ultimate parent or a designated entity in a jurisdiction with an active exchange arrangement. The Article 223 WW bis CGI text is the relevant legal starting point. A group cannot infer the exemption from the fact that another country has Pillar 2 rules. It must verify the designated entity, the jurisdiction, the effective exchange relationship for the year, the content transmitted and the evidence of acceptance.

The central-filing decision should be written, not left in an email chain. It should name the ultimate parent, the designated filer, the jurisdiction of filing, the French constituent entities covered, the fiscal year, the applicable exchange agreement and the person responsible for confirming that the exchange will occur. If one French entity is excluded from the central filing or if a local French payment remains due, the decision must say so explicitly. Central GIR filing and French payment are not interchangeable concepts.

The legal framework also contains implementing rules for the content and format of the return. Article 46 quater-0 ZZD of Annex III to the CGI addresses information such as the currency and the reporting data. The Annex III provisions on the Pillar 2 declarations should be consulted with the applicable form instructions. These details matter when a group’s consolidation software uses one currency, the French accounts use another and the XML schema requires a consistent reporting currency.

The payment layer has its own control. Article 1679 decies of the CGI governs the payment of the complementary tax and the liquidation statement. The Article 1679 decies CGI text should be checked for the liable entity, the designated payer and the telepayment process. The statutory wording links the amount to the liquidation statement and electronic payment. In practical terms, the group should not assume that a GIR receipt proves that the payment has been made. If the computation produces a French top-up amount, reconcile the amount in the liquidation statement with the payment reference and the bank confirmation.

The French reporting architecture also distinguishes the notification of the filing position. Article 46 quater-0 ZZB of Annex III provides the implementing detail for the indication made by an entity in its tax filing. The official ZZB text should be read with the form instructions and the designation decision. This is a small control with a large practical effect: an entity can have a central GIR filer and still need to state its position in the French tax-return environment.

The group should run a reconciliation before transmission:

1. The ultimate-parent name and tax identifier match the consolidated accounts and the GIR.
2. Every French constituent entity appears once, with the correct legal name and identifier.
3. Any French permanent establishment is mapped to the correct foreign legal entity and jurisdiction.
4. The designated filer and exchange jurisdiction match the written central-filing decision.
5. The fiscal-year dates, currency and revenue threshold test are consistent across the GIR, tax computation and internal memo.
6. The liquidation statement is either filed and paid or supported by a documented no-payment conclusion.
7. The portal receipt, XML file hash, validation log and payment evidence are stored together.

This reconciliation is especially important where the foreign parent owns several French companies. One subsidiary may have the software and personnel to transmit the central GIR; another may have the French tax liability; a third may be a branch or permanent establishment with a different data path. The filing map should identify each entity’s role rather than use “the French group” as a vague substitute for legal responsibility.

B. What should a foreign-owned group do after a missed or rejected filing?

If the group has not completed the filing by 1 September 2026, it should act immediately and preserve an evidence trail. The first step is to establish what failed: no scope decision, missing group data, absent tax identifier, designation not documented, XML validation failure, portal access, payment problem or an internal approval delay. A general statement that “the foreign parent is handling it” is not an adequate diagnosis. The French entity needs to know whether it is covered by a central return and whether any French filing or payment remains outstanding.

The second step is to make the filing as soon as the system permits, using the correct fiscal year and entity information. Do not change the year-end or omit a French entity merely to make the XML pass. If the platform rejects the file, save the exact error message, the rejected XML, the schema version, the date and time, and the identity of the person who attempted the transmission. Correct the data at source, rerun validation, and retain the new file alongside the rejected version. A later reviewer should be able to see what was wrong and why the corrected return is reliable.

The third step is to contact the French tax administration where the issue is technical or the legal filing route is uncertain. The Ministry’s extension notice gives the DGFiP assistance contact for questions about the first campaign. The group should use the official contact route, describe the entity, fiscal year, filing role and error, and retain the response. A contact request does not automatically replace the filing, but it can document a genuine platform or interpretation problem and provide a controlled next action.

Where the foreign parent filed centrally, obtain proof rather than relying on an assertion. Ask for the submitted return, the acceptance receipt, the designated filer’s legal identity, the exchange jurisdiction, the relevant exchange status and the list of French entities included. Verify that the central filing actually covers the first French campaign. A foreign tax return bearing the words “Pillar 2” is not necessarily the French GIR contemplated by Article 223 WW bis.

Where the French entity may owe top-up tax, calculate the amount even if the GIR is delayed. A late information return and an unpaid tax amount are different risks. The group should quantify the French amount, identify the liable entity, check the payment route under Article 1679 decies and obtain advice on interest, penalties, correction and any available administrative relief. It should not record “no French tax” simply because the GIR could not be generated.

Where no top-up tax is due, document why. The supporting analysis may rely on the safe harbour, effective-tax-rate computation, covered-tax treatment, exclusion, loss position, substance-based exclusion or the absence of a French constituent entity. The conclusion should identify the exact provision and data used. A no-payment conclusion is not the same as a no-filing conclusion. The GIR may still be required so that the administration can identify and assess the group’s position.

The legal correction route should be handled carefully. Article 223 WW permits the administration to request a corrected return in the event of manifest errors. The relevant wording refers to “erreurs manifestes” in the Article 223 WW CGI text. The group should therefore use a controlled correction process: identify the original filing, describe the error, mark the corrected fields, preserve the source evidence, transmit the corrected file through the available procedure and store the new receipt. Never overwrite the original XML or delete the portal confirmation.

The directors of a foreign parent and the French legal representative should agree who owns the remediation. A French subsidiary may be unable to access the parent’s consolidation data, while the foreign parent may not know the local tax account or French filing mandate. A short written responsibility matrix can avoid that gap. It should assign the group-perimeter decision, data production, XML generation, French notification, GIR submission, payment, portal monitoring and legal response.

For a newly acquired French company, the transaction documents should also be checked. Pillar 2 data may have been prepared by the seller before completion, but the post-completion company may now be responsible for the filing or for preserving the evidence. Review tax indemnities, completion accounts, pre-closing covenants, access to the consolidation system and any notice received from the French administration. The buyer should not assume that the acquisition date resets the group’s first-year deadline.

For a French subsidiary with a virtual office, outsourced accounting or a non-resident director, the filing responsibility remains a legal and tax matter rather than a question of physical presence. A registered office does not supply the group data; an accountant’s engagement letter does not automatically transfer director-level oversight; and the absence of a French-resident parent does not remove French reporting duties. The group should identify the person with practical authority to approve the submission and make sure that the mandate covers the relevant digital filings.

The group should also plan for future years. The 1 September 2026 extension is tied to the first campaign. It should not be built into the permanent calendar without checking the statutory fifteen-month period, the eighteen-month first-year rule where it applies, the relevant year-end and any new administrative notice. Put the deadline in the French company’s legal calendar, but link it to the ultimate parent’s consolidation calendar. A local reminder alone will not produce the group data in time.

Finally, create a post-filing review. Confirm the public or portal acceptance status, reconcile the data in the French tax account, check the payment ledger, answer any administration message and record the final responsibility owner. If the group discovers that a French entity was omitted, escalate promptly. A transparent correction with a coherent evidence file is materially easier to defend than a late discovery followed by unexplained edits.

The short action sequence for a missed deadline is therefore:

1. Confirm scope and the relevant fiscal year from the consolidated accounts.
2. Identify whether the French entity files locally or is covered by a valid central filing.
3. Separate the GIR, the notification and any liquidation/payment statement.
4. Validate the XML and submit or correct without changing the legal perimeter.
5. Calculate any French top-up tax independently of the GIR transmission status.
6. Contact DGFiP through the official route if the platform or designation is unclear.
7. Preserve rejected files, receipts, error messages, calculations and all written explanations.

This approach addresses the practical risk without overstating the legal consequence of a missed date. The right response depends on the group’s scope, the filing role, the amount due and the reason for the delay.

Conclusion

For a foreign-owned French company, the 1 September 2026 Pillar 2 date is a targeted first-campaign deadline, not a general obligation imposed on every French business. The decisive questions are the group’s consolidated revenue, the multinational group perimeter, the French entity’s status and the designated filing route. A small French subsidiary can be a constituent entity of a very large group, while an independent company with foreign customers may remain outside the regime.

The compliance file should separate four conclusions: whether the group is in scope; whether the French entity must notify; whether the GIR is filed locally or centrally; and whether French top-up tax must be liquidated and paid. The official texts—especially Articles 223 VJ, 223 VL, 223 VM, 223 WW, 223 WW bis and 1679 decies of the CGI—should be matched to the group’s accounts, XML file and receipts. If the deadline was missed, file or correct promptly, document the cause, obtain central-filing evidence where relevant and seek a controlled response from DGFiP. Do not confuse an accepted GIR with a paid tax amount, or a no-payment result with a no-filing result.

Need a quick opinion on your case

Your situation can be reviewed by telephone within 48 hours with a lawyer from the firm.

We can help you identify the French filing route, the group documents to preserve and the immediate response to a missed or rejected Pillar 2 filing.

Call +33 6 46 60 58 22 or use the contact form for the firm.

For a business established or operating in Paris or Île-de-France, the review can also address the French entity’s local tax-account, representation and filing practicalities.