Euro Tax Flash from KPMG's EU Tax Centre

On May 18, 2026, the OECD released further materials on the Global Minimum Tax (GMT), including:

• Guidance on central filing and exchange of the GloBE Information Return (GIR),
• Updates to the Central Record, and
• Administrative guidance on the application of the Transitional UTPR Safe Harbour to MNE groups with 52-53 week fiscal years.

The releases come shortly before the June 30, 2026, GIR filing deadline for calendar-year groups and are expected to be particularly relevant for multinational enterprise (MNE) groups in addressing practical implementation and compliance considerations.

On May 18, 2026, the OECD released documents on the GMT, including materials on central filing and exchange of the GIR, updates to the Central Record, and administrative guidance on the application of the Transitional UTPR Safe Harbour in the particular case of MNEs with 52-53 week fiscal years.

Under the initial design of the GMT framework, MNEs were expected to benefit from the option of central GIR filing, whereby a single return filed in one jurisdiction would be exchanged with other relevant jurisdictions, thereby reducing local filing obligations. However, practical implementation challenges have arisen, including:

• Slow activation of bilateral exchange relationships under the GIR Multilateral Competent Authority Agreement (MCAA).
• Failure by some Member States to transpose DAC9 (which allows for GIR exchanges within the EU) .
• Absence of local GIR filing portals in some jurisdictions.

Absent further coordination, these issues could result in multiple local GIR filing requirements for MNEs. 

To address these challenges, the OECD published a common understanding among 33 out of the 38 jurisdictions implementing the GMT for 2024. These jurisdictions are listed in an annex and are also noted as expected to be ready for central filing before May 31.

To the extent permitted by domestic law, parties to the common understanding have committed to waiving penalties and refraining from enforcing local GIR filing obligations provided that the MNE centrally files its GIR in a listed jurisdiction and submits the required local notifications. This approach is subject to a number of limitations:

• Jurisdictions may require local filing if GIR information is not exchanged by December 31, 2026.
• Certain jurisdictions (including the Bahamas, North Macedonia, Slovak Republic and Vietnam) have not joined the common understanding.
• Greece and Poland only provide relief for central filings made in other EU Member States.

In light of the above, MNEs may wish to:

• Review their chosen central filing jurisdiction, potentially taking into account the extent of activated exchange relationships.
• Identify the jurisdictions where the MNE is subject to GMT that did not sign on to the OECD guidance on central filing.
• Identify jurisdictions that do not have an active bilateral exchange relationship with the jurisdiction where they intend to central file as of June 30, 2026.
• Identify the jurisdictions that do not have an active bilateral exchange relationship with the jurisdiction where they centrally file as of December 31, 2026.

For more information, please refer to a detailed report by KPMG International.

The OECD updated the Central Record to include additional jurisdictions, namely the Bahamas, Kenya, Kuwait and Oman, with Qualified Domestic Minimum Top-up Tax (QDMTT) rules and safe harbours, bringing the total number of listed jurisdictions to 50.

For more information, please refer to a detailed report by KPMG International.

The OECD further released administrative guidance addressing the application of the Transitional UTPR Safe Harbour to MNE groups with 52–53 week fiscal years. The guidance confirms that the safe harbour may apply to fiscal years ending up to January 3, 2027, thereby addressing a potential gap in the application of the transitional rules.

For more information, please refer to a detailed report by KPMG International.

With limited time remaining before the first GIR filing deadline, MNE groups may wish to closely monitor further OECD and domestic developments, including clarifications from local tax administrations, and ensure that filing positions are aligned with evolving administrative guidance.

Should you have any queries, please do not hesitate to contact KPMG’s EU Tax Centre, or, as appropriate, your local KPMG tax advisor.