France has published Decree No. 2024-1126 of 4 December 2024 in the Official Gazette, which establishes regulations for the implementation of the Pillar 2 global minimum tax (GloBE) rules introduced by the Finance Law for 2024 (Law no. 2023-1322 of 29 December 2023). As previously reported, this includes the introduction of the Pillar 2 income inclusion rule (IIR) and the undertaxed payment/profit rule (UTPR) in order to ensure a minimum tax level of 15% for MNE groups with annual consolidated revenue of at least EUR 750 million in at least two of the preceding four fiscal years. A qualified domestic...