The introduction below frames practical priorities for French wealth and holding structures facing two concurrent waves of tax change: the OECD-led GloBE (Pillar Two) minimum tax and the EU’s DAC8 reporting regime for crypto-assets. It summarises immediate compliance obligations, identifies structural vulnerabilities, and proposes a pragmatic review path tailored to holding companies, family offices and other patrimonial vehicles in France.

Given recent transpositions and administrative guidance, French taxpayers and their advisers must align legal form, governance, accounting and record-keeping with both GloBE reporting requirements and the new automatic exchange rules for crypto-asset transactions under DAC8. The recommendations that follow draw on the latest OECD and EU materials and French administrative guidance current as of 22 October 2026.

Overview of GloBE and DAC8

GloBE (the OECD’s global minimum tax, often called Pillar Two) establishes an effective tax rate floor of 15% for large multinational enterprises and introduces mechanisms such as the Income Inclusion Rule (IIR) and undertaxed payments rules (UTPR) to collect top-up tax where the ETR falls below that floor. Implementation continues to evolve through OECD toolkits and national transpositions.

DAC8 amends the EU Directive on Administrative Cooperation to create a Crypto-Asset Reporting Framework (CARF): crypto-asset service providers and certain intermediaries must report EU-resident clients’ transactions for automatic exchange between Member States. The DAC8 framework entered into force and began applying to reportable transactions from 1 January 2026, with Member States implementing national procedures and standardised formats.

Although these regimes target different objectives,tax-rate equalisation for GloBE and tax transparency for DAC8,their combined effect on French wealth structures is material: tax base computations, data collection, and cross-border information flows are all affected, and coordination of compliance across corporate and wealth vehicles is essential.

Identify which French entities fall in scope

Not all French holding vehicles or family offices are automatically within GloBE scope, but an entity that is part of an MNE group exceeding the size thresholds or that sits under a consolidated group within scope will be affected; France implemented Pillar Two elements through domestic legislation transposing the EU Directive and associated decrees. Advisers should map group boundaries, ultimate parent entity (UPE) positions, and relevant financial years to determine exposure.

For DAC8, the primary reporting obligation sits with crypto-asset service providers (CASPs) and other intermediaries; however, individuals and entities holding crypto-assets via such providers will have their transaction data reported by the provider to tax authorities. Family offices that custody or broker crypto-assets,directly or via third-party platforms,need to confirm whether their arrangements trigger reporting under DAC8 and whether they must supply documentation to providers.

Separate French tax rules and administrative positions also affect domestic-only holdings (for example the Qualified Domestic Minimum Top-up Tax, QDMTT, or reporting decrees for the GloBE information return). This means some purely domestic structures may face additional top-up tax mechanics or local reporting obligations even when the group’s UPE is outside the EU.

Review accounting, tax bases and ETR calculation

Preparing for GloBE requires an early review of the tax base and accounting treatment used by French holding entities: allocation of income and expense, adjustments required by the GloBE rules (e.g., permanent differences, related-party adjustments, and exempt income treatments), and the treatment of intra-group financing and royalties can materially affect the ETR. Use of local taxable income as reported under French GAAP/IFRS and the alignment of taxable and accounting bases should be validated.

Substance-based income exclusions, qualified domestic top-up mechanisms, and flow-through entity rules can all change the effective GloBE computation. Structures that rely on deductible intra-group interest, management fees or low-tax jurisdictions should model ETR outcomes under the Pillar Two mechanics to identify potential top-up tax exposure and timing of payments.

For DAC8-adjacent items, ensure that crypto gains or losses are correctly classified under French tax rules and that transaction records reconcile to custodial and exchange statements: missing or inconsistent accounting between books and platform reports will complicate both GloBE ETR calculation and DAC8 data responses.

Strengthen reporting, documentation and governance

French entities in scope of GloBE must complete the GloBE Information Return (GIR) and maintain supporting documentation for calculations; French decrees set out GIR content and centralised filing procedures, and the administration has provided specific guidance and transitional arrangements for filing deadlines. Firms should centralise record-keeping and appoint clear internal ownership for GloBE compliance.

Under DAC8, CASPs and reporting intermediaries must implement customer onboarding and due-diligence processes that capture tax residency and identity information, retain the required audit trails, and prepare reports in the standardised electronic formats established by EU implementing regulation. Wealth structures that use multiple custodians must coordinate data flows to ensure completeness and to respond promptly to queries from platforms or tax authorities.

Governance measures should include clear escalation channels between tax, compliance and treasury teams, pre-approved templates for GloBE disclosures, and secure archiving policies for DAC8 data (including long retention periods where national rules require it). These controls reduce operational risk during audits and information exchanges.

Operational changes to consider for holding groups

Re-examine intercompany agreements, service-charge policies and financing arrangements: documentation must reflect actual functions, assets and risks to support any substance claims and to justify transfer pricing and deductible positions under GloBE scrutiny. Where possible, renegotiate terms or implement substance-creating measures that align with the group’s commercial reality.

Cash management and dividend policies should be stress-tested for additional top-up tax costs and potential timing mismatches between local tax payments and Pillar Two top-ups. Consider whether domestic top-up mechanisms (QDMTT) and withholding arrangements alter repatriation strategies for patrimonial holdings.

For family offices and holding companies investing in crypto-assets, reassess custody models: cold wallets, self-custody and non-EU custodians each carry distinct reporting and due-diligence consequences under DAC8. When providers are obliged to report, the completeness and accuracy of the provider’s data may determine the intensity of subsequent tax authority enquiries.

Practical checklist and implementation timeline

Immediate (next 1,3 months): map group entities, identify in-scope entities for GloBE and identify crypto exposures and service providers for DAC8; collect historical tax and accounting data necessary to model prior-year ETRs and to support future GIR filings. Early mapping reduces the risk of late surprises and enables prioritized remediation.

Medium term (3,9 months): run ETR simulations, update intercompany agreements and transfer-pricing policies where necessary, implement or upgrade onboarding and KYC procedures for crypto holdings, and centralise documentation for GIR submission and DAC8 reporting requests. Also plan for systems or vendor changes to capture and reconcile reportable transaction data.

Ongoing (9,18 months): finalise GIRs and other filings within French deadlines, monitor developments in OECD administrative guidance and French implementing rules, and maintain a continuous improvement loop between tax, legal and treasury functions to mitigate future compliance and reputational risk. Note that France has indicated specific transitional filing arrangements and administrative tolerance where companies make reasonable efforts to comply.

France and EU technical standards are still evolving, and the interaction between Pillar Two mechanics and national measures can produce fact-driven outcomes for holding structures. Given the potential exposure,both in tax and reporting terms,an early, integrated review of legal form, accounting, governance and IT capability is essential to reduce uncertainty and avoid late remediations.

Our recommendation is to prioritise a triage: (1) identify entities and crypto positions in scope, (2) stabilise data and documentation necessary for GIR and DAC8 reporting, and (3) implement targeted structural or operational changes where modelling shows material Pillar Two top-up or reporting risk. Advisers experienced in French tax, cross-border compliance and crypto reporting should be engaged early to tailor actions to the facts of each patrimonial structure.

If you would like a bespoke checklist, modelling of GloBE ETR outcomes, or an audit-defence review of your DAC8/data-exchange readiness, our firm can provide a structured diagnostic and an implementation roadmap tailored to French holdings and family office arrangements.

Contact us to schedule a compliance diagnostic and to prioritise measures based on materiality and timing, so your structures are documented and defended against both Pillar Two and DAC8 scrutiny.