Concept
The GloBE Information Return is the standardised return that shows a tax administration how a group computed its effective tax rate and top-up tax for every jurisdiction in which it operates. Preparing the GIR is a separate obligation from declaring and paying top-up tax: the second runs on each jurisdiction's own procedures, and the OECD asks jurisdictions to refrain from collecting, through the ordinary tax return, data points that the GIR does not contain (OECD, GloBE Information Return, January 2025, para. 3).
The filing architecture has three elements. Article 8.1.1 of the Model Rules requires every Constituent Entity to file the GIR with its local tax administration. Article 8.1.2 removes that obligation where the Ultimate Parent Entity or a Designated Filing Entity files for the whole group in a jurisdiction that has a Qualifying Competent Authority Agreement in effect with the local one, so the local administration receives the sections relevant to it through exchange. Article 8.1.3 leaves the local entity with a notification identifying who files and where. That is the whole practical story: central filing removes the filing, never the notification.
The tax itself — the QDMTT, IIR and UTPR rule order, the safe harbours and the implementation map — belongs to the master article on Pillar Two. This page covers the compliance perimeter: deadlines, contents, exchange and penalties.
Deadlines
The standard deadline is 15 months after the end of the Reporting Fiscal Year; for the first year in which the group falls within the rules, 18 months (Articles 8.1.6 and 9.4.1 of the Model Rules). National legislation reproduces both figures verbatim. Ireland defines the specified return date as the last day of the 15-month period and, for a transition year, of the 18-month period (Taxes Consolidation Act 1997, section 111AAH as inserted by Finance (No. 2) Act 2023). The United Kingdom uses the same 15 and 18 months and adds a floor of its own: where the computed date falls earlier, the deadline moves to 30 June 2026 (Finance (No. 2) Act 2023, Schedule 14, paras 10(9), (11) and (12)).
The Inclusive Framework agreed that filing and notification deadlines for any Fiscal Year fall no earlier than 30 June 2026, short 2024 reporting years included. For calendar-year groups that was the first real Pillar Two deadline.
| Reporting Fiscal Year | GIR filing deadline | Exchange deadline |
|---|---|---|
| FY2024, calendar year, jurisdiction applying the rules from 2024 | 30 June 2026 (18 months, first year) | 31 December 2026 (6 months, first exchange) |
| FY2025, calendar year, same group | 31 March 2027 (15 months) | 30 June 2027 (3 months) |
| FY2025 in Hong Kong, where the regime started in 2025 | 30 June 2027 (18 months); separate top-up tax notification due by 30 June 2026 | 31 December 2027 |
The Hong Kong row shows that notification and return run on different clocks: the Inland Revenue Department requires a top-up tax notification within six months after the end of the Reporting Fiscal Year, a full year ahead of the return itself. The Hong Kong regime is covered in the regional article.
What the return actually carries
The GIR consists of a general section covering the group as a whole and jurisdictional sections on a single template, one for every jurisdiction where the group operates, including jurisdictions that never enacted the GloBE Rules. The general section identifies the Filing Constituent Entity, sets out the corporate structure with the GloBE status of each Constituent Entity, and carries the summary table of Section 1.4. The jurisdictional sections split into a short Section 2 for jurisdictions where a safe harbour or exclusion applies and a full Section 3 with the ETR computation, the Top-up Tax computation and its allocation. Computations under a QDMTT that meets the Safe Harbour requirements are reported in the same jurisdictional sections. In the January 2025 document the data-point template runs to about 30 pages and the explanatory guidance to roughly fifty more.
Section 1.4 is built as a risk indicator. The exact ETR for a jurisdiction never appears in it; instead the group reports the 2.5-percentage-point band into which the ETR falls between 0% and 30%, with everything above shown as a single "above 30%" line. Top-up Tax is likewise reported in bands: none payable, below EUR 1 million, below 5, 25, 50, 75, 100 and 250 million, and at or above EUR 250 million. Jurisdictions where no Excess Profit arose because the Substance-based Income Exclusion exceeded Net GloBE Income are flagged separately.
Only the Ultimate Parent Entity jurisdiction receives the return in full. Everyone else receives exactly what their own taxing rights require, which is the dissemination approach.
| Recipient | What it receives |
|---|---|
| Ultimate Parent Entity jurisdiction | The whole GIR |
| Jurisdiction with taxing rights under the GloBE rule order, including a QDMTT jurisdiction in respect of itself | General information and corporate structure, plus the jurisdictional sections for those jurisdictions over which it has taxing rights |
| UTPR jurisdiction with a UTPR Percentage of zero | Only the excerpt of Section 3.4.3 on the attribution of Top-up Tax under the UTPR |
| QDMTT-only jurisdiction | The general section without the Section 1.4 summary |
Until the end of the transitional period — Fiscal Years beginning on or before 31 December 2028 but not including a Fiscal Year ending after 30 June 2030 — a group may elect the transitional simplified jurisdictional reporting framework and report adjustments to FANIL, current tax expense and deferred tax expense at jurisdictional rather than Constituent Entity level. The election is available only for jurisdictions where no Top-up Tax liability arises or where it need not be allocated Constituent Entity by Constituent Entity; where allocation is required, reporting stays at entity level. The simplification touches the format and not the computation: where a rule requires an entity-level calculation, the calculation is still done at entity level and only the aggregate is reported. It does not restrict a tax administration's right to seek supporting workpapers in a follow-up request.
Central filing and notification
By spring 2026 it became clear that the Article 8.1.2 mechanism was constrained by infrastructure: several jurisdictions had no working filing portal in place by the deadline, and bilateral exchange relationships remained unactivated. On 18 May 2026 the OECD published a common understanding on support for central GIR filing and exchange for the 2024 Reporting Fiscal Year.
Its substance is this. Thirty-seven jurisdictions apply a Qualified IIR or a QDMTT with effect from their 2024 Fiscal Year; they agreed, to the extent available under their domestic laws, either to waive penalties for failure to file a local GIR or not to enforce local filing before the relevant exchange deadline, provided the group filed the GIR centrally in one of the jurisdictions listed in the annex and filed the local notification on time. The annex lists 33 jurisdictions expected to be ready to accept central filing before 31 May 2026.
Two things here are routinely misread. First, the 33 are the jurisdictions in which a group may file centrally, and not the list of those granting the relief. Second, the local notification is mandatory everywhere and always; without it the relief does not operate.
The document has been updated twice since May and the participant list has changed. The version of 25 June 2026 recorded that the Bahamas and Greece had joined, and that the Slovak Republic joined except in respect of jurisdictions with which it has no activated exchange relationship. The version of 6 July 2026 added North Macedonia. As of this review, Vietnam is the only jurisdiction that has not joined. Poland joins only in respect of central filing in EU Member States listed in the annex; Japan accepts central filing only for Fiscal Years beginning on or after 1 April 2024, since its QIIR applies from that date.
The relief is conditional in time. A jurisdiction that waived penalties or refrained from enforcing local filing may take enforcement action if the centrally filed GIR has not reached it by the relevant exchange deadline.
Exchange: the GIR MCAA and its arithmetic
Outside the EU the legal framework for exchange is the Multilateral Competent Authority Agreement on the Exchange of GloBE Information. Section 3 sets three deadlines: ordinary exchange no later than three months after the filing deadline in the sending jurisdiction; six months for the first Reporting Fiscal Year in respect of which the legal and operational framework for filing is in effect in that jurisdiction; and three months from receipt for a return filed after the deadline. Transmission is in XML through the OECD Common Transmission System.
That is where the 31 December 2026 date comes from: the FY2024 filing deadline is 30 June 2026, it is the first Reporting Fiscal Year, and six months are added. Section 4 adds a procedure for exchange that does not happen: the local entity notifies its own competent authority, which approaches the sending authority, and the sending authority must state the reason and the expected exchange date within one month.
The European layer: DAC9
Within the EU, exchange is arranged separately. Council Directive (EU) 2025/872 of 14 April 2025, published in the Official Journal on 6 May 2025, inserts Article 8ae and Annex VII, containing the standard template for the Top-up tax information return, into Directive 2011/16/EU on administrative cooperation. The Directive itself constitutes a Qualifying Competent Authority Agreement between Member States, so no separate agreement is needed among them.
The timing mirrors the OECD mechanism: three months after the filing deadline, six for the first Reporting fiscal year, three months from receipt for a late return. One adjustment is purely European: the first exchange will in any case take place no earlier than 1 December 2026. Member States that elected the deferral under Article 50 of Directive 2022/2523 begin exchanging when the election period ends. The Directive does not harmonise penalties: Member States set their own, subject to the requirement that they be effective, proportionate and dissuasive.
Transposition was due by 31 December 2025 and did not happen everywhere. On 30 January 2026 the Commission sent letters of formal notice to ten Member States — Belgium, Bulgaria, Czechia, Greece, Cyprus, Malta, the Netherlands, Portugal, Romania and Sweden (January infringements package). Seven of the ten closed the point by the summer: on 8 July 2026 reasoned opinions went to Belgium, Bulgaria and Cyprus, which have two months to comply before the Commission may refer the cases to the Court of Justice with a request for financial sanctions (July infringements package). For a group with entities in those three Member States the practical reading is straightforward: assuming that information will reach them automatically under DAC9 is premature.
Penalties
Penalties are national, and the spread between jurisdictions is measured in orders of magnitude.
| Jurisdiction | Failure to file the return or notification | Inaccuracy and other failures |
|---|---|---|
| United Kingdom | £100 if filed within three months of the submission date, £200 within six months, thereafter £200 plus £60 for each day; on a third successive failure these rise to £500 and £1,000 | Inaccurate information falls under the general regime of Schedule 24 to the Finance Act 2007; failure to submit the self-assessment return runs to 20% of the unpaid tax |
| Ireland | €10,000 for each complete month of delay in filing the return or the notification of filer, capped at 48 months | €10,000 for failure to comply with a Revenue notice; €10,000 on a person who deliberately assists in delivering an incorrect return |
| Netherlands | Vergrijpboete under Article 13.3 of the Wet minimumbelasting 2024 where the failure is due to intent or gross negligence; the amount is set case by case | Until 31 October 2026 no verzuimboete is imposed for late filing or late payment under Article 14.3 |
| Hong Kong | Penalty levels are set by sections 80O, 82 and 82A of the Inland Revenue Ordinance | Separate service provider liability under section 80P |
The UK and Irish figures come from the statutes (Schedule 14, paras 42 and 43; section 111AAAB TCA 1997). The Dutch position is recent: a decree of the State Secretary for Finance of 30 July 2026 added paragraph 28j to the Besluit Bestuurlijke Boeten Belastingdienst for the bijheffing-informatieaangifte obligation and, at the same time, suspended late filing and late payment penalties until 31 October 2026.
Above the national rules sits the common understanding on transitional penalty relief. Annex C to the OECD GIR document asks jurisdictions to give careful consideration before applying penalties where a group has taken reasonable measures — where it has, in good faith, put appropriate systems in place. The term is deliberately undefined and is read against local practice; the examples given are a mistake of fact that is reasonable in the circumstances, errors reasonably attributable to unfamiliarity with the rules in the initial years, a reasonable interpretation of an unclear requirement, and actions that do not reduce Top-up Tax liability at all. The Transition Period covers Fiscal Years beginning on or before 31 December 2026 but not including a Fiscal Year ending after 30 June 2028 (OECD, Safe Harbours and Penalty Relief). The relief does not extend to avoidance, fraud or abuse, and it does not remove the obligation to correct errors and pay unpaid Top-up Tax with interest.
Ireland shows what this looks like after national implementation: the transitional relief is written into the statute with the same dates and a reasonable care condition. Where no such provision exists, the relief remains a matter of administrative discretion.
What a group should do
The sequence is the same for every Reporting Fiscal Year.
- Map the full perimeter: every jurisdiction of operation, split into those applying the GloBE Rules, those applying only a QDMTT, and those applying neither. A jurisdictional section is completed for the last category too.
- Choose the central filing jurisdiction from the annex to the common understanding, weighing which jurisdictions of operation it has activated exchange relationships with.
- File the Article 8.1.3 notification in every jurisdiction where a Constituent Entity is located, against the local deadline, which can fall considerably earlier than the return deadline.
- File the GIR centrally on time and retain the workpapers for follow-up requests, from which the simplified jurisdictional framework offers no protection.
- After the exchange deadline, verify that the information reached each jurisdiction of operation and prepare local filings where it did not.
Where a deadline has been missed, the order of priority reverses. Notifications go first: they are cheap, and in several jurisdictions their absence is what collapses the relief. The return follows — in Ireland the counter runs on complete months, so filing before the end of the current month is worth money. In parallel, the group builds the record for reasonable measures: correspondence with advisers, a documented data collection process, an account of the specific error. Arguing about the computation is beside the point where the penalty attaches to lateness rather than to the tax.
Q/A
Does central filing remove the local notification requirement?
No, and this is the one element of the structure that admits no exception. The Article 8.1.3 notification tells the local tax administration who files the GIR for the group and in which jurisdiction. The common understanding conditions both the waiver of penalties and the forbearance on local filing on that notification having been filed by the local deadline. Without it the relief does not operate, even where the return itself was filed on time.
What happens if exchange does not occur by 31 December 2026?
A jurisdiction that waived penalties or refrained from enforcing local filing may resume enforcement. Section 4 of the GIR MCAA sets out the procedure: the local entity notifies its own competent authority that the information has not arrived, that authority approaches the sending one, and the sending authority has one month to state the reason and the expected exchange date. For a group the practical point is that confirmation of filing guarantees nothing; receipt is what needs to be tracked.
Is exchange within the EU guaranteed if the return is filed in a Member State?
No. Directive (EU) 2025/872 itself serves as a Qualifying Competent Authority Agreement between Member States, but transposition by the 31 December 2025 deadline is incomplete: on 30 January 2026 the Commission opened infringement procedures against ten Member States, and on 8 July 2026 it issued reasoned opinions to Belgium, Bulgaria and Cyprus. The first exchange under the Directive will in any case not take place before 1 December 2026.
Does a jurisdictional section have to be completed for a country that never enacted the GloBE Rules?
Yes. The GIR includes GloBE computations for every jurisdiction where the group has Constituent Entities, including non-implementing ones, since otherwise jurisdictions with taxing rights could not verify the rule order and the allocation of Top-up Tax. That country receives nothing through exchange, however: the dissemination approach does not address the position of non-implementing jurisdictions.
Does transitional penalty relief protect against penalties for computational errors?
Partly, and not unconditionally. Annex C to the OECD GIR document is a common understanding rather than a rule: it asks jurisdictions to refrain from penalties where the group has taken reasonable measures, for Fiscal Years beginning on or before 31 December 2026 but not including a Fiscal Year ending after 30 June 2028. Ireland has carried this into statute with a reasonable care condition; elsewhere it turns on administrative discretion. Avoidance, fraud and abuse are outside the relief, and correcting the error and paying the tax with interest is required in any event.
What does the simplified jurisdictional reporting framework give?
The right to report adjustments to financial accounting net income and to tax expense at jurisdictional level instead of Constituent Entity by Constituent Entity. It is available for Fiscal Years beginning on or before 31 December 2028 but not including a Fiscal Year ending after 30 June 2030, and only for jurisdictions where no Top-up Tax arises or where it need not be allocated at entity level. The computation itself follows the ordinary rules: where a rule requires an entity-level calculation, it is still done at entity level. The framework does not limit a tax administration's right to request an entity-by-entity breakdown in a follow-up request.