The GloBE Information Return

What is the GloBE Information Return?

The GloBE Information Return (GIR) is the standardised filing through which an MNE group discloses its Pillar 2 computations to tax authorities. It serves a dual purpose: it is the mechanism through which the group demonstrates compliance with the GloBE rules, and it is the source document that tax authorities use to verify that the correct amount of top-up tax has been calculated and allocated.

The GIR was developed by the OECD Inclusive Framework to ensure a consistent format across jurisdictions. Rather than each country designing its own filing requirements (which would multiply the compliance burden for groups operating in many jurisdictions), the GIR provides a single, standardised template that is filed once and shared between tax administrations through an exchange of information mechanism.

The GIR is a substantial document. For a large MNE group with operations in dozens of jurisdictions and hundreds of constituent entities, the GIR will contain thousands of data points covering corporate structure, income, taxes, adjustments, elections, and top-up tax allocation. It is not a simple tax return; it is closer in scope to a comprehensive compliance dossier.

The four sections of the GIR

The GIR is organised into four main sections, each of which captures a different aspect of the GloBE compliance computation:

Section 1: General information

This section captures identifying information about the MNE group and the filing entity:

• Name and tax identification number of the UPE
• Jurisdiction of the UPE
• Fiscal year covered by the return
• Accounting standard used for the consolidated financial statements
• Currency used for reporting
• Identity of the filing entity (if different from the UPE)
• Details of any designated filing entities and their jurisdictions
• Confirmation of whether the group is filing for the first time (which may affect certain transitional provisions and deadlines)

Section 2: Corporate structure

This section provides a comprehensive map of the MNE group's constituent entities and their jurisdictional allocation:

• List of all constituent entities, including their legal names, tax identification numbers, and jurisdictions of location
• Ownership structure and percentages for each entity in the chain
• Identification of the UPE, intermediate parent entities (IPEs), partially-owned parent entities (POPEs), and any joint ventures (JVs) or minority-owned constituent entities (MOCEs)
• Identification of excluded entities and the basis for their exclusion
• Details of permanent establishments and their allocation to jurisdictions
• Changes to the group structure during the fiscal year (acquisitions, disposals, mergers, entity formations, or liquidations)

This section is essential for tax authorities to understand the group's footprint and to determine which entities and jurisdictions are relevant for their review.

Section 3: ETR computation and top-up tax

This is the most data-intensive section. For each jurisdiction where the group has constituent entities, it includes:

• GloBE income computation: Starting financial accounting income, each category of adjustment (excluded dividends, excluded equity gains, FX adjustments, stock-based compensation, policy disallowed expenses, etc.), and the resulting Net GloBE Income
• Covered tax computation: Current tax expense, deferred tax adjustments (including recasting at 15%), DTL recapture amounts, allocation of CFC taxes, and the resulting Adjusted Covered Taxes
• Jurisdictional ETR: The computed ETR for the jurisdiction
• SBIE computation: Eligible payroll costs, eligible tangible asset values, applicable carve-out rates, and the resulting SBIE amount
• Top-up tax computation: Top-up tax percentage, excess profit, jurisdictional top-up tax, and any additional top-up tax (from DTL recapture or post-filing adjustments)
• De minimis exclusion: Whether the de minimis exclusion has been elected and the supporting three-year averages
• Safe harbour application: Whether a transitional CbCR safe harbour or QDMTT safe harbour has been applied, which test was passed, and the supporting data

For jurisdictions where a safe harbour applies, the full ETR computation is not required; only the safe harbour test results and supporting data need to be disclosed.

Section 4: Top-up tax allocation

This section sets out how the jurisdictional top-up tax is allocated to specific entities and collected through the applicable mechanism:

• Identification of the collection mechanism for each jurisdiction (QDMTT, IIR, or UTPR)
• Allocation of top-up tax to individual constituent entities based on their share of excess profit
• For IIR jurisdictions: the parent entity bearing the charge and its ownership share
• For UTPR jurisdictions: the allocation formula (employees, tangible assets) and the resulting allocation to each UTPR entity
• Credits for QDMTT amounts already paid
• Net top-up tax payable by entity and by jurisdiction

Who files the GIR?

The default filing entity is the UPE. The GIR is filed in the jurisdiction of the UPE with the local tax authority, which then exchanges the information with the tax authorities of other jurisdictions where the group operates.

However, the rules allow for alternative filing arrangements:

Designated filing entity

The MNE group may designate a constituent entity in another jurisdiction to file the GIR on behalf of the group. This may be appropriate where:

• The UPE jurisdiction has not adopted the GloBE rules and does not have a filing obligation
• The group prefers to centralise its GloBE compliance function in a jurisdiction other than the UPE's
• An intermediate parent entity is responsible for the IIR and is in a better position to compile the return

When a designated filing entity is used, the group must notify the relevant tax authorities of the designation and ensure that the designated entity's jurisdiction has an information exchange mechanism in place with other relevant jurisdictions.

Local filing requirements

Some jurisdictions may require local constituent entities to file a simplified notification or a local top-up tax return (particularly where a QDMTT applies) in addition to the centralised GIR. These local requirements vary by jurisdiction and must be tracked separately.

Filing deadlines

The GIR must be filed within specific timeframes after the end of the fiscal year:

For example, for a group with a fiscal year ending 31 December 2024:

• If this is the first year the GloBE rules apply, the GIR is due by 30 June 2026 (18 months).
• For subsequent years (e.g., fiscal year ending 31 December 2025), the GIR is due by 31 March 2027 (15 months).

The extended 18-month deadline for the first year acknowledges the additional lead time groups need to establish their GloBE compliance processes and data collection systems.

Exchange of information between jurisdictions

One of the central design principles of the GIR is that it is filed once and shared widely. The exchange of information works as follows:

1. The filing entity submits the GIR to the tax authority in its jurisdiction.
2. That tax authority then exchanges the GIR (or relevant portions of it) with the tax authorities of all other jurisdictions where the MNE group has constituent entities.
3. The exchange is conducted under a multilateral competent authority agreement that governs the confidentiality, use, and timing of the information exchange.

This exchange mechanism is modelled on the CbCR exchange framework that has been in operation since 2018. Tax authorities use the received GIR to:

• Verify that the QDMTT (if applicable) has been correctly calculated and paid in their jurisdiction
• Confirm that the IIR or UTPR has been correctly applied
• Identify potential audit targets or areas of concern
• Cross-check data against other sources (tax returns, CbCR reports, financial statements)

Common challenges in preparing the GIR

Groups preparing their first GIR typically encounter several challenges:

• Data collection at scale: The GIR requires entity-level data across every jurisdiction. Collecting this data from local finance teams, particularly for smaller or more remote entities, is logistically demanding and requires clear templates, instructions, and quality controls.
• Consistency of accounting: The GIR must be based on the accounting standard used in the consolidated financial statements. Entities using local GAAP may need reconciliation adjustments, which must be documented and included in the return.
• Elections documentation: All elections made (or not made) must be disclosed and their impact quantified. This requires a clear election register and a process for documenting the analysis behind each choice.
• Structural changes: Acquisitions, disposals, and restructurings during the year create complexity in the corporate structure section and may affect how income and taxes are allocated. Year-on-year consistency checks are important.
• Audit trail: Tax authorities will expect the GIR to be supported by a complete audit trail linking every figure to its source data. Building this trail into the compliance process from the outset is far more efficient than trying to reconstruct it after the fact.
• Coordination with local filings: Where local QDMTT or notification requirements exist, the data in the GIR must be consistent with local filings. Discrepancies can trigger queries and additional compliance costs.

Amendments and corrections

If errors are identified in a filed GIR, the group may need to submit a corrected return. The rules for amendments vary by jurisdiction, but the general framework allows for corrections within a specified period (typically aligned with the five-year post-filing adjustment window for covered taxes).

Material corrections that affect the ETR or top-up tax computation may trigger additional top-up tax or a refund, depending on the direction of the error. Groups should have a process for identifying and assessing post-filing adjustments and for determining whether a corrected GIR is required.