Pillar Two Reporting Obligations: Tax Authorities Warn of Common Errors

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The French tax administration has identified recurring errors in the filing of form 2065-INT-SD, which entities belonging to groups subject to country-by-country reporting (CbCR) requirements and/or the global minimum tax rules must file each fiscal year alongside their corporate income tax return (see Tax Authorities Publish New Form for CbCR, Pillar Two (28 January 2025)).

Paris

The most common errors include:

  • failure to identify the Ultimate Parent Entity (UPE) or the designated filing entity for the GloBE Information Return (GIR);
  • entities wrongly declaring themselves as the UPE;
  • French entities designated to file the GIR not indicating this in their own form 2065-INT-SD; and
  • mistakes in country code entries.

These errors could have substantial consequences and lead to penalties. The tax authorities therefore urge taxpayers to submit a corrected form 2065-INT-SD as soon as possible to rectify any inaccuracies.

The announcement by the tax authorities, which also provides additional filing instructions, is available here (in French only).

Report from Francesco De Lillo, Senior Associate, IBFD. Follow our reporting on this via our Tax News Service (subscribers only).