GloBE Information Return — First Filing Deadline June 30, 2026

What Is the GloBE Information Return?

The GloBE Information Return (GIR) is the central reporting document under the OECD's BEPS Pillar Two framework — the 15% global minimum tax that over 50 countries have now enacted into domestic law. The GIR is not a tax return in the traditional sense; it is a comprehensive information filing that documents an MNE group's structure, entity-level financials, effective tax rates, and top-up tax calculations across every jurisdiction where the group operates.

Think of the GIR as the Pillar Two equivalent of a Country-by-Country Report (CbCR), but significantly more detailed. Where a CbCR captures high-level revenue, profit, employees, and taxes per jurisdiction, the GIR requires granular entity-level data sufficient to compute the GloBE Effective Tax Rate (ETR) for each jurisdiction and determine whether a top-up tax is owed — and by whom. A group with 200 entities across 30 countries must provide compliant GIR data for each of them.

The OECD published its standardised GIR template alongside Administrative Guidance in 2023, and the template has since been refined through subsequent guidance releases. Under the Side-by-Side Package agreed in December 2025 (effective January 1, 2026), key simplifications were added — including a new Simplified ETR Safe Harbour that reduces the data burden for low-risk jurisdictions — but the core filing obligation remains.

Who Must File the GIR

An MNE group is required to file a GloBE Information Return if it meets both of the following criteria:

• Revenue threshold: The group's consolidated annual revenue is €750 million or more in at least two of the four fiscal years immediately preceding the current reporting year.
• Multi-jurisdictional presence: The group has constituent entities (subsidiaries, branches, permanent establishments) in at least two different jurisdictions.

Based on CbCR data and OECD estimates, approximately 8,000 MNE groups meet this threshold worldwide. That population includes virtually every Fortune 500 company, every FTSE 100 company, and a large proportion of mid-market multinationals that have crossed the €750 million threshold.

Groups that are in scope but have no constituent entities in a jurisdiction that has implemented Pillar Two are still likely required to file the GIR (or a local notification) to demonstrate that no domestic top-up tax is owed. The filing obligation is determined by each implementing jurisdiction's domestic legislation, not solely by the OECD model rules.

Three-Layer Compliance Structure

Pillar Two compliance operates in three distinct layers, and each layer has its own deadline. Conflating these layers is one of the most common errors tax teams make when planning their Pillar Two calendar.

Layer 1 — Registration / Notification

Most implementing jurisdictions require in-scope MNE groups to register or notify the tax authority of their Pillar Two status. This is typically the earliest deadline. In Singapore, for example, the registration deadline is June 30, 2026 (six months after the end of the 2025 fiscal year for calendar-year groups). Italy requires notification of the designated filing entity. Failure to register is often treated as a separate infraction from failure to file, with its own penalty regime.

Layer 2 — GloBE Information Return (GIR)

The GIR is the comprehensive group-level return covering all jurisdictions. Under the OECD's Administrative Guidance, no jurisdiction may set its GIR due date before June 30, 2026 for the transitional first filing year (18-month window from end of fiscal year 2024 for December year-end groups). In practice, many jurisdictions have set their deadline at exactly June 30, 2026. The GIR is submitted by the Designated Filing Entity (DFE) — typically the ultimate parent entity (UPE) or a surrogate entity — on behalf of the group. The DFE then notifies each jurisdiction where constituent entities are located.

Layer 3 — Domestic Top-Up Tax Return and Payment

If a jurisdiction's GloBE ETR falls below 15%, a top-up tax may be owed. The domestic top-up tax return — which triggers the actual tax payment — is typically due 15 months after year-end under standard rules, or 18 months for the transitional first year, meaning the payment deadline is generally the same as the GIR: June 30, 2026 for fiscal year 2024 returns. However, some jurisdictions (notably Australia) have set payment deadlines separately from information return deadlines.

The June 30, 2026 Deadline — Why It Cannot Be Extended

The June 30, 2026 date was established by the OECD's Administrative Guidance as a floor: no jurisdiction implementing GloBE rules may require filing before this date for the transitional first year. This gives groups with a December 31, 2024 fiscal year-end an 18-month window from year-close to complete and file the GIR.

However, the June 30 date is not a soft deadline — it is built into the domestic tax legislation of each implementing jurisdiction. Unlike CbCR filing, there is no broadly available extension mechanism under Pillar Two. The OECD has not signalled any global extension, and individual countries are constrained from unilaterally extending the date because doing so could trigger a UTPR charge from other jurisdictions that have already filed and assessed top-up tax. An extension in one country can create asymmetric compliance obligations.

Groups relying on the Transitional CbCR Safe Harbour — which allows simplified computation using CbCR data — still need to file the GIR with the safe-harbour election included. The safe harbour reduces the amount of data required inside the GIR, but it does not eliminate the filing obligation itself.

Country-by-Country Deadlines and Status

Pillar Two has been enacted in 50+ jurisdictions. The table below covers the most significant jurisdictions for MNE groups by share of global FDI flows, reflecting guidance available as of May 2026.

The United States has not enacted GloBE rules. US-headquartered groups are subject to GIR filing obligations only in the jurisdictions where their non-US constituent entities are located. However, US parents may still face UTPR top-up taxes imposed by other jurisdictions on the US parent entity's undertaxed profits — a risk mitigated but not eliminated by the OECD's Side-by-Side Package.

Italy: Technical Specifications Approved April 8, 2026

Italy's Tax Authority (Agenzia delle Entrate) issued an Order on April 8, 2026 approving the detailed technical specifications for electronic submission of the GloBE return (Dichiarazione fiscale Globe). This is one of the most significant recent developments for groups with Italian operations, as Italy is a major hub jurisdiction for European sub-groups and holding structures.

The Italian filing system uses the classic Agenzia telematic approach: the filer prepares a structured electronic file in the approved format, runs it through Agenzia's control software (version 1.0.0, released March 31, 2026), and submits the validated file through the telematic channel. Groups unfamiliar with Italian telematic filings should engage local service providers immediately, as the validation step requires Italian-language software familiarity.

Italy's Three-Document Filing Structure

Italian Pillar Two compliance involves three separate submissions:

• Comunicazione di designazione: The notification identifying which entity will submit the GIR on behalf of the Italian constituent entities (the "designated filing entity" notification)
• Comunicazione Rilevante (GIR): The GloBE Information Return itself, covering all group entities in all jurisdictions as required by the OECD standard
• Dichiarazione fiscale Globe: The domestic Italian GloBE top-up tax return for any DMTT or IIR tax owed by Italian constituent entities to the Italian treasury

Singapore: Registration Portal Opens May 2026

Singapore enacted its Multinational Enterprise (Minimum Tax) Act (MMT Act) in 2024, implementing both an Income Inclusion Rule (IIR) and a Domestic Top-Up Tax (DTT). The Inland Revenue Authority of Singapore (IRAS) has confirmed that the online registration portal for Pillar Two obligations will open in May 2026 — this month.

In-scope MNE groups with at least one constituent entity or joint venture located in Singapore, or at least one reverse hybrid entity incorporated in Singapore, must register for the MTT and DTT. The registration deadline is June 30, 2026 — six months after the end of the group's first financial year to which the MMT Act applies (December 31, 2025 for calendar-year groups). Groups that fail to register on time face a 10% surcharge on any DTT or MTT liability subsequently assessed.

What Singapore's Registration Requires

The IRAS registration form — draft version released in January 2026 — collects the following key information:

• Ultimate Parent Entity (UPE) identity and jurisdiction of tax residence
• Designated Filing Entity details (if different from UPE)
• All Singapore constituent entities and their entity types under GloBE rules
• Revenue threshold confirmation (€750 million test)
• Fiscal year-end and applicable safe harbour elections (Transitional CbCR Safe Harbour, Simplified ETR Safe Harbour)
• Contact details of the responsible officer for Singapore Pillar Two compliance

Other Key Jurisdictions — Recent Guidance

South Africa

South Africa enacted the Global Minimum Tax Act in 2024. In April 2026, SARS issued an alert clarifying the key registration, notification, and filing deadlines for 2026. South Africa's DMTT applies to fiscal years starting on or after January 1, 2024, with both registration and GIR filing due by June 30, 2026 for calendar-year groups. South Africa is one of the first Sub-Saharan African jurisdictions to implement Pillar Two, and groups with African holding structures should assess whether South Africa is the appropriate DFE jurisdiction.

United Kingdom

HMRC's Pillar Two rules (under Finance Act 2023) implement both IIR and DMTT. HMRC published detailed filing guidance confirming June 30, 2026 as the first GIR deadline for UK constituent entities. Importantly, HMRC has confirmed that UK constituent entities of groups whose UPE is not in the UK must still file a UK notification identifying the DFE responsible for the group GIR — even if the GIR itself will be filed in another jurisdiction.

Australia

The Australian Taxation Office (ATO) published comprehensive lodging, paying, and other obligations guidance. Australia has set the GIR filing deadline at June 30, 2026, but the payment of any top-up tax is deferred to September 30, 2026, giving groups a three-month window between information filing and payment. This split deadline is relatively unusual compared to other jurisdictions and may assist Australian-headquartered groups managing cash flow around the filing period.

European Union Member States

All 27 EU member states are required to have implemented the EU Pillar Two Directive (2022/2523) by December 31, 2023. Most have done so. The June 30, 2026 MNE Top-Up Tax Information Return deadline applies across the EU. Several member states — including Germany, France, the Netherlands, Ireland, and Belgium — have published their domestic technical filing procedures. Groups with complex EU sub-group structures should confirm whether any member state requires a local notification even where the DFE is in another EU member state, as transposition variations persist.

Penalties and Surcharges for Non-Compliance

Penalty regimes vary significantly across jurisdictions, but the direction is consistent: regulators are taking GIR non-compliance seriously, and penalties are structured to scale with the size of the non-compliant group.

10-Step Action Plan for the June 30 Deadline

With 57 days remaining, the window for orderly preparation is closing. The following checklist reflects the sequence that tax advisory firms recommend for groups that have not yet completed their GIR preparation.

1. Confirm in-scope status: Apply the €750 million revenue test to fiscal years 2020–2023. Identify all group entities and jurisdictions.
2. Designate the filing entity (DFE): The UPE or surrogate DFE must be formally designated. Notify each implementing jurisdiction of the DFE's identity.
3. Map domestic filing obligations: For each jurisdiction where a constituent entity is located, confirm whether a local notification, local GIR, or GIR-by-exchange is required. Do not assume automatic exchange is in place.
4. Assess safe harbour eligibility: Determine whether the Transitional CbCR Safe Harbour or the Simplified ETR Safe Harbour (effective from fiscal years starting December 31, 2026 in most jurisdictions, or December 31, 2025 in some) is available for each jurisdiction. Safe harbours reduce data burden but require an election in the GIR.
5. Collect entity-level financial data: GIR requires pre-tax income, covered taxes, deferred tax position, payroll headcount, and tangible assets for every constituent entity — not just at jurisdiction level. Use the OECD's standard data template.
6. Compute GloBE ETR by jurisdiction: Apply GloBE adjustments (SBIE carve-outs, deferred tax adjustments, excluded dividends) to arrive at the adjusted covered taxes and GloBE income for each jurisdiction.
7. Identify top-up tax liabilities: Where GloBE ETR is below 15%, calculate the top-up tax and determine which rule (IIR at UPE level, UTPR, or local DMTT) collects it.
8. Register in all required jurisdictions: Complete registration/notification filings before the deadline. Singapore's portal opens this month — act immediately.
9. Prepare and validate the GIR file: Prepare the GIR in the OECD XML schema format (or local equivalent where required, such as Italy's telematic format). Run validation checks before submission.
10. File and retain documentation: Submit by June 30, 2026. Retain all supporting workpapers, data sources, and safe-harbour elections for the expected post-filing compliance review period (typically 5–7 years).

What Happens After Filing?

The June 30, 2026 filing is the start, not the end, of the Pillar Two compliance cycle. Once the first GIR is filed, groups should expect:

• Exchange of information: Tax authorities will exchange GIR data through the DAC9 mechanism (EU) and equivalent bilateral Competent Authority Agreements. Information filed in one jurisdiction will be visible to tax authorities in others.
• Post-filing queries: Tax authorities in several jurisdictions have indicated they will issue post-filing questionnaires or information requests for groups with GloBE ETRs close to the 15% threshold.
• Annual compliance cycle: The GIR is an annual obligation. The fiscal year 2025 GIR (for calendar-year groups) will be due by March 31, 2027 under standard 15-month rules — a tighter window than the transitional 18-month window used for the first cycle.
• Interplay with the Side-by-Side Package: Groups benefiting from the US-specific safe harbour under the OECD's January 2026 Side-by-Side Package must elect that safe harbour in their first GIR. The election is irrevocable for the relevant fiscal year.

For more detail on how the Side-by-Side Package interacts with the GIR and US parent structures, see the Pillar Two Side-by-Side Package 2026 guide. For a foundational explanation of GloBE mechanics, see the BEPS Pillar Two explained guide.