On 11 September 2026, the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) issued three documents on the Global Minimum Tax (GMT):
- Updated Global Anti-base Erosion (GloBE) Information Return (GIR), reflecting the Side-by-Side (SbS) Package and providing clarifications on various issues under the existing template;
- Administrative Guidance on Explicitly Conditional Taxes and the use of Local Financial Accounting Standard under a Qualified Domestic Minimum Top-up Tax (QDMTT) in case of mismatching fiscal periods; and
- Terms of Reference and Assessment Methodology for the Full Legislative Review for the qualification status of jurisdiction’s GMT regimes.
This release is the first set of substantive GMT guidance issued by the IF since January 2026, with more expected towards the end of this year.
KPMG International has issued a publication highlighting the key technical points, sharing observations on what these developments mean for in-scope Multinational Enterprises (MNEs), and outlining other practical considerations.
If you have any questions on the practical implications of these latest releases for your business, please speak to the authors or your usual KPMG in the UK contact.
