GloBE Information Return (GIR)

The GloBE Information Return (GIR) is the standardised international reporting format that multinational groups must file under the Pillar 2 minimum tax (GloBE). It contains all information required for calculating the Qualified Domestic Minimum Top-up Tax (QDMTT), Income Inclusion Rule (IIR), and Undertaxed Profits Rule (UTPR) at both jurisdiction and entity level.

• Annual filing standardised per OECD specifications
• Contains consolidated financial data, tax adjustments, and GloBE-specific calculations
• Information exchange between tax authorities via the GloBE Multilateral Competent Authority Agreement (MCAA)
• Filing obligation in the ultimate parent entity's jurisdiction or in each jurisdiction where constituent entities are located
• Surrogate filing by the ultimate parent possible; local filing as fallback mechanism

The need for a standardised reporting format arose from the GloBE Model Rules (December 2021), which created the legal framework for the Pillar 2 minimum tax. The actual development of the GIR as a standardised reporting format took place within the OECD/G20 Administrative Guidance framework: Transitional Safe Harbours were first defined in February 2023, a detailed GIR consultation draft followed in July 2023, and the final GIR standard was adopted in December 2023 — including the XML schema (XSD) and rules for cross-border information exchange via the GloBE Multilateral Competent Authority Agreement (MCAA).

Numerous countries implementing GloBE rules from 2024 onwards (e.g., Germany, the Netherlands, the United Kingdom) have incorporated GIR filing requirements into their domestic legislation.

All in-scope MNE groups under the GloBE rules are required to file the GIR:

• MNE groups with consolidated annual revenue ≥ EUR 750 million in at least two of the four fiscal years immediately preceding the tested fiscal year
• Groups temporarily below the threshold but historically above it may also be included
• Exceptions for certain governmental entities, international organisations, and pension funds
• De minimis exclusion: jurisdictions with revenue < EUR 10 million and profit < EUR 1 million may be excluded from top-up tax and partially from GIR reporting
• Initial phase of international activity exclusion (up to 5 years for certain MNE groups)

The GIR must include entity-level and jurisdiction-level data for each jurisdiction in which the group has constituent entities.

• Annual filing with the tax authority of the UPE or as surrogate filing by a designated entity
• Complete disclosure of revenues, profits, taxes, and employee counts per jurisdiction
• GloBE-specific calculations including Effective Tax Rate (ETR) per jurisdiction
• Identification and calculation of top-up taxes (IIR, UTPR, QDMTT)
• Filing deadline: generally 15 months after the end of the fiscal year (18 months in transition year)
• Data exchange with other tax authorities via the GloBE Multilateral Competent Authority Agreement (MCAA)
• Standardised XML schema (XSD) as the technical foundation for electronic filing and automatic exchange of information
• Simplified reporting requirements for jurisdictions qualifying for the Transitional CbCR Safe Harbour (transition period for fiscal years starting on or before 31 December 2026 but no later than 30 June 2028)

1 correction:
- Official URL uses deprecated OECD URL format (no longer functional)
4 updates:
- Missing key_dates: OECD Administrative Guidance packages (Feb 2023, Jul 2023, Dec 2023)
- Missing detail: GloBE MCAA for inter-jurisdictional exchange not mentioned
- Missing detail: XML schema and technical specification of GIR not mentioned
- Missing key_dates: Safe harbour transitional rules and STTR not mentioned
4 clarifications.