France has recently clarified its position on the centralised filing and exchange of the GloBE Information Return, commonly known as the GIR.

For multinational groups preparing for their first Pillar Two reporting campaigns, this clarification comes at a decisive moment. After months of regulatory analysis, simulations and initial data structuring, the focus is now shifting to execution: notification, filing, documentation, controls and auditability.

At first glance, the topic may sound administrative. It is not.

Behind the centralised filing of the GIR lies a broader question: how can multinational groups organise Pillar Two compliance across jurisdictions in a coordinated, traceable and auditable way?

In other words, Pillar Two is no longer only about calculating top-up tax. It is becoming a matter of tax governance, international coordination and operational control over tax data.

A French clarification in line with the OECD approach

On 28 May 2026, the French tax authority published a clarification on the centralised filing and exchange of the GIR.

This position follows the common understanding published by the OECD on 18 May 2026, which aims to preserve the administrative benefits of the central filing mechanism for the first reporting campaigns.

The issue is practical: some filing portals and exchange relationships between tax authorities may not yet be fully operational when the first GIR filing deadlines arise.

France has confirmed that it intends to apply this transitional approach for returns whose filing deadline falls no later than 31 December 2026.

In practice, during this period, France accepts the principle of a centralised GIR filing by the ultimate parent entity or by a designated filing entity, provided that the filing is made in a jurisdiction participating in the international agreement.

Where these conditions are met, French constituent entities should not, in principle, be required to file the GIR locally, as long as the return can be transmitted to the French tax authority within the expected timeframe.

This point is important for an international audience: the French clarification is not a standalone EU-wide rule. It is France’s domestic position within a broader OECD-coordinated approach. Other jurisdictions may apply similar transitional approaches, but the scope, conditions and practical consequences depend on local law and on the relevant exchange mechanisms.

What centralised GIR filing is meant to achieve

The logic of centralised filing is simple.

Without a coordinated mechanism, a multinational group could face multiple local GIR filing obligations across different jurisdictions, each with its own portal, format, timetable and administrative expectations.

The centralised filing mechanism is designed to avoid this fragmentation. It allows a single GIR to be filed in a participating jurisdiction, before the relevant information is exchanged between tax authorities.

For multinational groups, this can represent a significant administrative simplification.

But it does not remove the underlying compliance obligations.

The GIR must still be prepared on time. Notification obligations must still be met. The data must be complete, reliable and usable. And the group must remain able to demonstrate the steps taken to comply with its filing obligations.

The simplification concerns the filing channel. It does not reduce the requirement for a robust process.

A transitional tolerance, not a compliance shortcut

The French approach is based on a pragmatic logic.

The French tax authority has indicated that it will take into account good-faith steps taken by multinational groups to comply with their GIR filing obligations under the centralised filing and exchange mechanism.

It also indicates that a lenient approach may be applied in relation to penalties where the absence of a local filing in France results exclusively from the implementation of this transitional centralised filing and exchange mechanism.

But this tolerance remains conditional.

It requires, in particular, that the group has complied with its notification obligations in France and that the GIR has been filed on time in a participating jurisdiction.

Another key point must not be overlooked: if the French tax authority does not receive the GIR within the expected timeframe, it may contact the group in order to enforce the local filing obligation. In that case, late filing penalties could apply until the group meets its obligations in France.

France’s position therefore provides flexibility, but not a waiver of operational responsibility.

Why international exchange becomes central

The French clarification is part of a broader movement: the gradual organisation of international exchange of GloBE information.

The purpose of this framework is to allow tax authorities in participating jurisdictions to receive the information they need, even when the GIR is filed centrally in another jurisdiction.

For multinational groups, this is a critical issue.

Pillar Two is built on an international logic: jurisdictional calculations, multiple local obligations, consolidated group data, numerous entities and domestic rules still being stabilised.

The GIR is therefore a global tax document, but one with local consequences.

This is why groups need to monitor not only whether the GIR has been filed, but also whether the information has been effectively exchanged between the relevant tax authorities.

Administrative simplification does not remove operational complexity

For tax and finance teams, this clarification is welcome. Under certain conditions, it can prevent an immediate multiplication of local GIR filings for the first reporting campaign.

But it should not be interpreted as a general simplification of Pillar Two compliance.

Groups still need to pay close attention to:

• notification obligations in each relevant jurisdiction;
• whether the central filing jurisdiction participates in the international approach;
• filing deadlines;
• the effective transmission of the GIR to local tax authorities;
• the ability to file locally if the exchange mechanism does not work as expected;
• the documentation of good-faith compliance efforts.

The message is clear: centralised filing can simplify the procedure, but it requires a strong internal compliance framework.

A group that does not control its GloBE data, validation workflows, methodological choices or filing calendar will not solve these issues through centralised filing alone.

What this means for tax and finance teams

This development confirms a broader point: Pillar Two is no longer only a matter of regulatory interpretation.

It requires tax and finance teams to build an operating model that connects several dimensions:

• GloBE data collection;
• entity-level and jurisdiction-level validation;
• calculations and simulations;
• GIR preparation;
• compliant file generation;
• data retention;
• documentation of assumptions, choices and adjustments;
• audit readiness.

The challenge is not only tax-related. It is also organisational, technical and data-driven.

With the GIR, groups must be able to produce consistent information at international level, but also explain how that information was built: where the data comes from, how it was controlled, which assumptions were used, which adjustments were made and how the final filing output was generated.

Tax data is becoming a strategic asset

With Pillar Two, tax data is changing status.

It is no longer only data used for calculation or one-off compliance. It becomes strategic data, shared across tax, finance, consolidation, reporting and sometimes local systems.

In this context, the ability to centralise data, secure workflows, document assumptions and generate compliant outputs becomes decisive.

Regulatory interpretation remains essential. But it is no longer sufficient.

Successful Pillar Two compliance also depends on the quality of the data foundation, the robustness of internal processes and the ability to justify each stage of the reporting cycle.

This is where many groups are discovering the real difficulty of Pillar Two: not only understanding the rule, but executing it in a reliable, documented and repeatable way.

From regulatory preparation to operational execution

For groups facing their first GIR filing deadlines, the priority is now to move from preparation to execution.

Tax and finance teams need to be able to answer very concrete questions:

• Is the GloBE data available, complete and usable?
• Do local contributors understand what is expected from them?
• Are controls, validations and adjustments properly documented?
• Can calculations be replayed, justified and audited?
• Can the required filing output be produced in the expected format?
• Is the organisation ready to manage centralised filing while remaining able to respond locally if required?

This operational dimension is now central.

The success of a Pillar Two reporting campaign depends as much on understanding the rules as it does on coordinating contributors, securing validation workflows and documenting the process from source data to final filing.

The French clarification does not only change practical filing modalities. It is a reminder that Pillar Two compliance must be treated as an end-to-end process.

How kShuttle supports multinational groups

With GMT Insight, integrated into the ExRP platform, kShuttle helps multinational groups structure and manage their Pillar Two obligations.

The solution supports the reporting cycle from GloBE data collection to GIR preparation, integrating calculations, simulations, controls, audit trail and documentation.

From an operational perspective, GMT Insight enables tax and finance teams to organise their campaigns around a structured and controlled process: entity-level data collection, validation workflows, jurisdiction-level monitoring, data history, simulations and production of expected reporting outputs.

GMT Insight also supports key Pillar Two requirements, including transitional safe harbour eligibility calculations, ETR calculations by category and jurisdiction, QDMTT and IIR calculation and distribution, data freeze when the GIR is produced, production of the GIR in XML format, corrective declarations where required and retention of GIR data.

For groups preparing for their first reporting campaigns, the objective is clear: secure data availability, reduce manual adjustments, strengthen controls and rely on an environment capable of producing compliant reporting outputs within the required timeframe.

In a regulatory environment that is still evolving, GMT Insight helps turn Pillar Two complexity into a controlled, traceable and audit-ready process.

Conclusion

France’s clarification on the centralised filing of the GIR marks an important step in the operational implementation of Pillar Two.

It brings welcome pragmatism for multinational groups, while reinforcing the need for rigorous organisation, reliable data and precise management of reporting obligations.

For companies in scope, the priority is clear: anticipate, document and secure their Pillar Two operating model now.

The GIR is not just a file to be submitted. It is the visible outcome of a complete process: data collection, calculation, validation, documentation, retention and auditability.

In the first Pillar Two reporting campaigns, the difference will not only be made by the ability to understand the rules.

It will be made by the ability to execute them.

Go further

Looking to secure your Pillar Two reporting campaign and prepare your GIR production?

kShuttle supports multinational groups in structuring GloBE data, organising validation workflows, documenting calculations and producing compliant reporting outputs.

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