OECD Clarifies GloBE Information Return (GIR) Central Filing

Before the 18 May OECD Announcement

Most groups had been anticipating that they would file their GIR in a single jurisdiction, with this jurisdiction’s tax administration then responsible for sharing the GIR with other relevant jurisdictions, i.e. the ‘central filing process’. The information shared with other jurisdictions would be limited to certain relevant parts of the GIR and would satisfy the MNE’s requirement to file a GIR locally that they would otherwise face.

However, to date, many jurisdictions have been slow to sign and activate bilateral exchange relationships based on the OECD’s GIR Multilateral Competent Authority Agreement (MCAA) and some EU member states are yet to implement DAC9, the Directive that provides for central filing within the EU. This would potentially have meant that many more local GIR filings would be needed.

After the 18 May OECD Announcement

33 out of the 38 jurisdictions implementing Pillar Two from 2024 have agreed to waive penalties and forgo enforcement for the absence of a local GIR filing (to the extent permissible under local law), provided that an MNE centrally files their GIR in one of the 33 jurisdictions and files the local GIR notification form.

In theory, this means that MNEs should be able to rely in many instances on the GIR central filing mechanism. Practically, there remain some unanswered questions on whether such relief is permitted under domestic law, and if it is, how it will be provided. The KPMG International overview provides more information and commentary on this.

On 19 May 2026, HMRC published confirmation that the UK supports the approach set out by the OECD with details of the transitional approach that will apply in the UK where the filing deadline for the GIR is no later than 31 December 2026.

In summary, if the GIR is centrally filed in line with the OECD’s guidance and HMRC receive the relevant GIR information from the other authority within six months of the filing deadline then local filing of the GIR will not be enforced in the UK and penalties will generally not apply. To benefit from this treatment the group must submit a valid overseas return notification (ORN) to HMRC on time. The GIR should have already been submitted at the time that the ORN is made for it to be valid.

Despite the announcement, there are still a plethora of global and local filing deadlines and requirements. MNE groups should ensure they have a detailed compliance plan in place and are aligned on their approach to filing across jurisdictions. If you would like to discuss the implications for your group, please speak to the authors or your usual KPMG UK Pillar Two contact.

For further information please contact:

• Kashif Javed
• Qasim Javid