OECD: Updated GloBE Information Return released as part of new Pillar Two implementation package
Package also includes the framework for legislative peer reviews and additional administrative guidance on explicitly conditional taxes and QDMTTs.
The OECD/G20 Inclusive Framework on BEPS today released a package to support the implementation and consistent application of the Pillar Two rules, including:
- Updated GloBE Information Return (GIR)
- Terms of Reference and Assessment Methodology for the Full Legislative Review
- Administrative guidance to address the treatment of explicitly conditional taxes and the use of local financial accounting standards under a qualified domestic minimum top-up tax (QDMTT)
Updated GloBE Information Return
The Inclusive Framework (IF) released an updated GIR, the standardized information return used by implementing jurisdictions to collect information needed to assess a multinational enterprise group's liability under the Pillar Two rules.
The updated GIR incorporates simplifications included in the side-by-side package agreed to by the IF in January 2026. The revisions apply to GIRs filed for fiscal years beginning on or after December 31, 2025.
Full legislative review process
The Terms of Reference and Methodology for the Full Legislative Review establish the framework that IF members will use to assess whether domestic rules implementing the Pillar Two rules are consistent with the GloBE Model Rules and Commentary.
Under the framework, IF members will conduct detailed peer reviews of implementing jurisdictions' legislation. When inconsistencies are identified, the IF may issue recommendations to assist jurisdictions in addressing those inconsistencies.
Administrative guidance
The IF also released additional administrative guidance addressing explicitly conditional taxes and the use of local financial accounting standards under a QDMTT.
The guidance confirms that taxes that explicitly apply to taxpayers only because they are subject to an income inclusion rule (IIR) or undertaxed profits rule (UTPR) in other jurisdictions are not creditable as covered taxes. The IF indicated that further guidance on other tax features that could result in a tax being treated as discriminatory, and therefore not treated as a covered tax, is expected by year end.
The guidance also clarifies that the QDMTT safe harbor continues to apply when a QDMTT is calculated using local financial accounting standards and the required QDMTT fiscal period does not align with the ultimate parent entity's fiscal year.
KPMG will follow up next week with a more comprehensive report detailing the OECD package.