France: Implemented Finance Bill for 2024 establishing global minimum tax transposing EU-Directive 2022/2523

On 31 December 2023, the Finance Bill for 2024 establishing global minimum tax transposing EU-Directive 2022/252 was implemented, with certain provisions applicable to the fiscal year beginning on 31 December 2023. Article 33 of the Law transposes the EU-Directive 2022/2523 of 14 December 2022 to ensure a worldwide minimum level of taxation for multinational enterprise groups and large domestic groups and outlines the reporting rules. The tax will be applicable to entities established in France with a consolidated turnover of EUR 750 million or more in at least two of the past four financial years. A group is defined as either entities connected through holding/control structures or entities with one or more permanent establishments. The Bill stipulates an additional tax that is due if the effective tax rate of a group of multinational companies or a national group in a state or territory is lower than the minimum tax rate of 15%.