OECD Updates GIR Format and Global Minimum Tax Guidelines

PARIS, DDTCNews - The Organisation for Economic Co-operation and Development (OECD) has updated the GloBE information return (GIR) and simultaneously published new administrative guidance on the implementation of the global minimum tax (GloBE).

The GIR update aims to support the implementation of GloBE, which has been revised through the side-by-side package.

"The updated GIR incorporates the simplifications included in the side-by-side package agreed by the Inclusive Framework in January 2026. These revisions to the GIR will apply only to GIRs filed in respect of Fiscal Years commencing on or after 31 December 2025," the OECD stated in an official release, cited on Monday (14/9/2026).

It should be noted that the GIR is a standard form that must be completed by constituent entities to report information on the application of GloBE.

To follow up on the GIR update approved by the Inclusive Framework, the OECD is also preparing an updated XML schema aligned with the GIR.

"The XML will be released shortly, allowing tax administrations and MNEs ample time to update their information collection, reporting, GIR filing and exchange systems," the OECD stated.

With regard to administrative guidance, the OECD has published provisions concerning explicitly conditional taxes.

Through the latest administrative guidance, the OECD has clarified that conditional or discriminatory taxes will not be treated as covered taxes under the GloBE rules.

A conditional tax is a tax which is designed to apply to a taxpayer of an in-scope multinational enterprise (MNE) group in a jurisdiction not eligible for the side-by-side safe harbour.

According to the OECD, such tax provisions are discriminatory against MNE Groups covered by GloBE and tend to favour groups that are exempt from GloBE coverage by virtue of the side-by-side safe harbour.

"This guidance confirms that taxes that explicitly apply to taxpayers only if they are subject to the IIR or UTPR in other jurisdictions are not creditable as covered taxes," the OECD explained.

The administrative guidance also contains provisions on the use of local accounting standards in computing the qualified domestic minimum top-up tax (QDMTT) where there is a difference in fiscal year between a constituent entity and the ultimate parent entity (UPE).

"Under certain conditions, a QDMTT may need to be calculated using financial accounts prepared based on the local financial accounting standard. This guidance clarifies that the QDMTT safe harbour continues to apply when the QDMTT is calculated based on the local financial accounting standard and the required QDMTT fiscal period does not align with the UPE’s fiscal year," the OECD stated in its release. (rig)