What happened?

France promulgated Law No. 2026-963 on 19 October 2026; it was published in the Official Journal on 20 October. The law authorises approval of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. The Senate and National Assembly legislative records confirm these dates.

Key details

France signed the agreement on 9 July 2025. Parliament’s definitively adopted text contains a single authorising article. Legislative authorisation, executive approval and activation of an exchange relationship are distinct steps; this report verifies the legislative milestone.

Who is affected?

The development matters to multinational groups with French constituent entities subject to Pillar Two, including GCC-linked groups with operations in France. It concerns GloBE Information Return (GIR) reporting arrangements, rather than a newly announced tax rate or safe harbour.

Effective date / timing

The new milestone is publication on 20 October 2026, not the original signature in 2025. The authorising law does not itself establish a new GIR filing deadline. We have not established from these sources that every relevant bilateral exchange relationship is operational.

Why it matters

The Senate’s substantive report explains that centralised GIR filing can reduce repeated local submissions. It also states that exchanges under the agreement depend on activation between the parties. The location of the ultimate parent or designated filing entity therefore matters to the reporting analysis.