Global Daily Tax News, Update To GloBE Information Return Welcomed By US, (Sep 14, 2026)

The OECD has released a revised version of the GLoBE Information Return, which incorporates the Side-by-Side Package agreed in January 2026. It will be used for Fiscal Years commencing on or after December 31, 2025.

The standard template for the GIR is intended to ensure that the information and tax calculations that an MNE Group is required to file under the GIR are sufficiently comprehensive to allow tax administrations to perform an appropriate risk assessment and to evaluate the correctness of a constituent entity's (CE's) tax liability under the GloBE Rules.

The agreement on a standardised information return does not preclude a tax administration from requesting necessary supporting information in follow-up requests to verify compliance with the GloBE Rules under that jurisdiction's domestic law.

The obligation to prepare a GIR is separate from the requirement to declare and pay taxes under a tax return. The operation of tax return filing and payment obligation rules is left to the determination of each Implementing Jurisdiction and is generally expected to be in line with those currently required under that jurisdiction's existing tax filing and payment procedures. This means that jurisdictions may, in some cases, require additional data points to be reported beyond the GIR for purposes of the preparation of the tax return (for instance, to convert the Top-up Tax liability into the domestic currency).

However, the OECD said jurisdictions should generally refrain from requiring the reporting of additional data points beyond the GIR as part of their routine tax return and payment requirements and any such information should relate, for instance, to liability, timing and method of payment or identification of the taxpayer and contact details, rather than the calculation of a CE's Top-up Tax liability.

The GIR consists of a general section, that applies to the MNE Group as a whole, and multiple jurisdictional sections based on a single template that need to be filled in for every jurisdiction where the MNE Group is operating. Annex A1 of this document contains the GIR data points needed to calculate an MNE's GloBE tax liability, while Annex A2 includes the accompanying explanatory guidance for these data points.

Under the general section, an MNE Group provides general information about the MNE Group as a whole, identifies the Filing Constituent Entity and outlines its corporate structure. Under the latest update, the general section allows also the MNE Group to make an election for the Side-by-Side Safe Harbour. As part of this section, the MNE Group also reports a summary table that provides a high-level overview of the application of the GloBE Rules in respect of every jurisdiction where the MNE Group is operating. If the SbS Safe Harbour applies, however, the Filing Constituent Entity need not complete the summary table (section 1.4) and certain items in the corporate structure (section 1.3).

The SbS Safe Harbour incorporates into the Pillar Two framework the so-called side-by-side arrangement, which notably includes an exemption for US-based multinational groups under Pillar Two. The arrangement provides that, despite the US not introducing a Pillar Two framework providing for the imposition of 15 percent tax on profits in each jurisdiction, other countries will cede the right to apply top-up tax on profits liable to US tax. Instead, US parented groups will be exempt from the Income Inclusion Rule and the Undertaxed Profits Rule in recognition of the existing US minimum tax rules to which they are subject.

As the US is the only jurisdiction recognized as having a qualifying regime under the arrangement, the SbS Safe Harbour and the simplifications incorporated into the new GIR specifically are for the benefit US-headquartered multinational companies.

The US Treasury Secretary, Scott Bessent, stated: "President Trump made clear on his first day in office that the Biden Administration's OECD global tax deal would have no force or effect in the United States. The revised GloBE Information Return delivers on a key element of President Trump's international tax agenda by putting the side-by-side framework into operation."

"It ensures that US-headquartered companies remain subject to US global minimum taxes, not overlapping foreign regimes, while significantly reducing unnecessary reporting and compliance burdens. By respecting US tax sovereignty and lowering compliance costs for American businesses, these new rules mark another important step toward restoring certainty and stability to the international tax system."

The Treasury Department said: "The revised GIR provides the mechanism for US-headquartered companies to make the side-by-side safe harbor election and reflects a critical part of implementing the side-by-side framework. It also establishes a standardized reporting framework for local minimum taxes based on the Pillar Two rules while limiting the dissemination of information reported for those purposes to the relevant jurisdiction."

"The side-by-side framework was designed to relieve US-headquartered companies from both the tax burden of overlapping global minimum tax regimes and the compliance burden associated with duplicative reporting. The revised GIR operationalizes a critical part of that framework by streamlining reporting obligations for US-headquartered companies while preserving the United States' tax sovereignty. The revisions provide the mechanism for US-headquartered companies to make the side-by-side safe harbor election and remove the potential for duplicative compliance obligations."

It noted: "The key provisions of the revised GIR include:

• Adding a field for US-headquartered companies to make the election to apply the side-by-side safe harbor, thereby exempting them from Pillar Two's IIR and UTPR.

• Providing specific exemptions from reporting for companies that elect the side-by-side safe harbor.

• Allowing taxpayers to apply the new rules protecting substance-based tax incentives that were also part of the side-by-side package, including – in the case of foreign-headquartered companies operating in the United States – the US R&D tax credit, from Pillar Two top-up taxes."