KPMG report: New guidance on global minimum tax framework
KPMG analysis and observations on the OECD package
The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (IF) on September 11, 2026, 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 (LFAS) under a qualified domestic minimum top-up tax (QDMTT) in case of mismatching fiscal periods.
- 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.
Read a September 2026 report prepared by KPMG LLP that highlights key technical points, includes observations on what these developments mean for in-scope multinational enterprises (MNEs), and outlines other practical considerations.