GloBE Information Return: Filing, Safe Harbors, and Deadlines

The GloBE Information Return is the standardized filing that in-scope multinational groups use to report their Pillar Two global minimum tax calculations for every jurisdiction where they operate, and for most large groups with calendar fiscal years the first return is expected to be due on June 30, 2026.¹ Instead of forcing every subsidiary to file separately in every country, the return consolidates the group’s minimum-tax figures into one document that tax authorities then share with each other through an automated exchange network. Getting the structure, data, and deadlines right matters, because a single error can ripple through dozens of jurisdictions at once.

Who Has to File

The GloBE rules apply to any multinational group whose consolidated financial statements show annual revenue above €750 million in at least two of the four fiscal years immediately before the year being reported.² A group that crosses the threshold in only one of those four years stays out of scope. Once a group qualifies, every entity in its consolidated structure is potentially subject to the rules, though the return itself is normally submitted by a single filing entity for the whole group.

Certain organizations are carved out entirely: government entities, international organizations, non-profits, pension funds, and investment funds or real estate investment vehicles that sit at the top of the group. Entities owned by these organizations are also excluded when they hold assets or invest funds and carry out only ancillary activities.² Excluded entities should still keep records demonstrating their status in case a tax authority challenges eligibility.

Legal responsibility for filing sits primarily with the Ultimate Parent Entity. If the UPE is in a country that has not adopted Pillar Two or does not require the return, the group can designate another entity to file on its behalf, and that Designated Filing Entity must be formally identified to the relevant tax authorities. When neither the UPE nor a designated filer submits, every constituent entity in the group may bear individual filing obligations in its own jurisdiction. That outcome multiplies workload and the risk of inconsistent data across countries.

How the Return Is Structured

The GIR is built from distinct sections, each aimed at a different audience within the chain of tax authorities that will eventually see the data.

The Filing Info section identifies the entity submitting the return, the group it belongs to, the reporting fiscal year, the accounting standard used, and the currency of the consolidated financial statements.³ The General Section maps the corporate structure: which entities exist, where they sit, how they relate, and which jurisdictions should receive which parts of the return through the exchange process. A high-level Summary table follows, giving receiving administrations a quick snapshot of the group’s GloBE position before they open the detailed numbers.

The most detailed part is the Jurisdiction Section, which repeats for every country where the group operates. Where no safe harbor applies, this section carries the full effective tax rate computation, the top-up tax calculation when the rate falls below 15%, and the allocation of that top-up tax. Where a safe harbor or exclusion applies, the data requirements are lighter.³ A separate UTPR Attribution section shows how any residual top-up tax is allocated among jurisdictions that have adopted the Undertaxed Profits Rule.

The Calculation the Return Documents

Every jurisdiction in the return answers one question: is the group’s effective tax rate in that country below 15%, and if so, how much additional tax is owed? Even where the answer is no top-up tax, the group must show its work.⁴

GloBE Income

The starting point is each entity’s financial accounting net income or loss from the consolidated financial statements. That figure is adjusted to strip out items that would distort cross-country comparisons: excluded dividends and equity gains or losses, deductions for illegal payments, certain stock-based compensation timing differences, functional-currency mismatches, and international shipping income.² The result is the jurisdiction’s GloBE Income or Loss.

Adjusted Covered Taxes

On the tax side, the calculation begins with the current tax expense from the financial statements and adjusts it. Tax credits refundable within four years are added back to covered taxes when they reduce the current tax expense; credits refundable after four or more years reduce covered taxes in the year they are granted. A deferred tax adjustment handles temporary differences and prior-year losses, but recognition of deferred tax assets and liabilities is capped at the 15% minimum rate so groups cannot inflate the ETR. A recapture mechanism ensures amounts claimed as covered taxes actually get paid within a set period.²

Effective Tax Rate and Top-up Tax

The jurisdictional ETR is Adjusted Covered Taxes divided by GloBE Income. At 15% or higher, no top-up tax arises and the reporting for that jurisdiction is comparatively light. Below 15%, the top-up tax percentage is the gap between 15% and the actual ETR. A jurisdiction with a 10% ETR, for instance, produces a 5% top-up tax percentage. That percentage is applied to the jurisdiction’s excess profit, which is GloBE Income minus the substance-based income exclusion. Any additional current top-up tax from prior-year adjustments is added, and any Qualified Domestic Minimum Top-up Tax already collected by the jurisdiction itself is subtracted.²

The Substance-Based Income Exclusion

The SBIE shelters income tied to real economic activity. It excludes a percentage of eligible payroll costs for employees in the jurisdiction plus a percentage of the carrying value of eligible tangible assets located there. The long-term rate for both is 5%, but a ten-year transition period begins with higher percentages that decline annually toward the permanent level. A group with real employees and physical operations in a low-tax country will owe less top-up tax than one that holds mainly intellectual property there with little substance.

Which Country Collects the Top-up Tax

Once a top-up tax obligation exists for a jurisdiction, three charging mechanisms determine which country actually collects it, in a set order.

The Qualified Domestic Minimum Top-up Tax takes first priority. If the low-tax jurisdiction has adopted a QDMTT, it collects the top-up tax domestically before any other country can claim it, which is why many jurisdictions have moved quickly to enact one.⁵ If a QDMTT does not fully cover the shortfall, taxes paid under a controlled foreign corporation regime (such as the US CFC rules) are allocated next and reduce the remaining top-up tax for that jurisdiction.

After that, the Income Inclusion Rule lets the parent entity’s jurisdiction impose the remaining top-up tax. The IIR flows down the ownership chain, so an intermediate parent may apply it if the ultimate parent’s jurisdiction has not adopted Pillar Two. The Undertaxed Profits Rule is the backstop, applying only when no QDMTT or IIR has collected the tax. The UTPR allocates the residual liability across adopting jurisdictions using a formula based on the group’s employees and tangible assets, and this allocation is reported in the return’s dedicated UTPR Attribution section.³

Transitional Safe Harbors

For fiscal years beginning on or before December 31, 2026, and ending on or before June 30, 2028, groups can use transitional safe harbors that treat the top-up tax in a jurisdiction as zero without running the full GloBE calculation.⁶ A jurisdiction qualifies if it meets any one of three tests using data from the group’s Country-by-Country Report:

De minimis test: total revenue in the jurisdiction is less than €10 million and profit before income tax is less than €1 million.⁷
Simplified ETR test: the simplified effective tax rate (income tax expense from the CbCR divided by profit) equals or exceeds the applicable transition rate for the fiscal year.⁷
Routine profits test: the group’s profit in the jurisdiction does not exceed the substance-based income exclusion amount calculated under the GloBE rules for entities there.⁷

When a jurisdiction qualifies, the Jurisdiction Section requires far less data for that country. Evaluate safe harbor eligibility early. It sharply reduces the workload for low-risk jurisdictions and frees resources for the full calculations elsewhere.

Deadlines and Notifications

The standard deadline for submitting the GIR is 15 months after the last day of the reporting fiscal year. For the first fiscal year that any entity in the group becomes subject to the GloBE rules, the deadline extends to 18 months.⁸ For most large groups with calendar fiscal years that first entered scope on January 1, 2024, the first return and associated notifications are expected to be due on June 30, 2026.¹

Most implementing jurisdictions require local notifications alongside the return. These typically identify which entity is filing the group’s GIR and where the primary filing will land. Missing a notification deadline can trigger a local filing requirement for the full GIR even when the parent has already submitted the global return elsewhere. Individual jurisdictions may also impose additional local reporting with earlier or separate deadlines, and the OECD maintains a compilation of these that is worth checking regularly as new obligations emerge.

Submission and International Exchange

Filing means uploading the completed XML file to the designated portal of the jurisdiction where the filing entity is located. The OECD publishes both a detailed template for the GIR and a technical XML schema that defines how the data must be formatted for electronic submission and international exchange.⁹ The schema was designed primarily for tax administrations exchanging data, but jurisdictions can also require it for domestic filings. Manual XML generation for a group with hundreds of entities is impractical, so most groups will rely on specialized tax compliance software to map internal data to the schema’s fields.

The Multilateral Competent Authority Agreement on the Exchange of GloBE Information creates the legal framework for the exchange.¹⁰ The receiving jurisdiction must share relevant sections with each participating country where the group operates. The General Section goes to jurisdictions where the ultimate parent or constituent entities are located. Each Jurisdiction Section goes to the country it covers, plus jurisdictions that might need to apply the IIR or UTPR.¹¹

The exchange must happen within three months of the filing deadline in the sending jurisdiction, extended to six months for the first reporting fiscal year. All data travels through the OECD’s Common Transmission System using the XML schema and mandatory encryption standards.¹¹ Receiving tax authorities cross-reference the return against local filings, so discrepancies are unlikely to go unnoticed.

Penalties and Record Retention

Penalties for non-compliance are set under each jurisdiction’s domestic law. There is no single penalty schedule in the OECD Model Rules. Some countries have adopted structures comparable to their existing international reporting penalties; others are still finalizing their enforcement regimes. Check the specific provisions in every jurisdiction where the group has constituent entities, and prioritize compliance resources accordingly.

Groups must retain all records that support the figures in the return, including the basis for every disclosure, safe harbor election, and top-up tax calculation. Retention periods vary. Australia, for example, requires records to be kept for at least eight years after they were prepared, or eight years after the transactions they relate to were completed, whichever is later.¹² Records must be kept in a format that lets a tax authority readily determine the entity’s top-up tax liability. Entities that qualify for an exclusion or exemption still need documentation proving their status if challenged.

What This Means for US-Parented Groups

The United States has not enacted Pillar Two legislation. Executive orders issued in early 2025 stated that the prior administration’s proposed OECD Pillar Two deal would have no force or effect for the United States, and Treasury subsequently secured an agreement with the more than 145 countries in the Inclusive Framework to have US-headquartered companies remain subject only to US global minimum taxes while exempting them from Pillar Two.¹³

That does not remove the return entirely from the picture for US-parented groups. Foreign subsidiaries in jurisdictions that have adopted Pillar Two remain subject to those countries’ rules, including the IIR, UTPR, and QDMTT. If a US-parented group has no Designated Filing Entity in an implementing jurisdiction, individual subsidiaries may face local filing obligations. The US CFC tax regime (referred to as the Net CFC Tested Income rules following the 2026 changes to the former GILTI provisions) is treated by the OECD framework as a blended CFC tax that reduces the top-up tax calculated for foreign jurisdictions, but it does not eliminate the group’s reporting obligations under Pillar Two in those countries.

1
OECD. Compilation of Additional GloBE Information Reporting Requirements
2
OECD. Pillar Two GloBE Rules Fact Sheets
3
OECD. GloBE Information Return Pillar Two XML Schema
4
OECD. GloBE Information Return January 2025
5
OECD. Global Anti-Base Erosion Model Rules Pillar Two
6
Australian Taxation Office. Transitional CBC Reporting Safe Harbour
7
OECD. Safe Harbours and Penalty Relief Global Anti-Base Erosion Rules Pillar Two
8
Canada Revenue Agency. Global Minimum Tax Get Ready to File
9
OECD. GloBE Information Return Pillar Two XML Schema
10
Fedlex. Multilateral Competent Authority Agreement on the Exchange of the Global Anti-Base Erosion GloBE Information
11
OECD. Multilateral Competent Authority Agreement Exchange of GloBE Information
12
Australian Taxation Office. Lodging Paying and Other Obligations for Pillar Two
13
U.S. Department of the Treasury. Treasury Secures Agreement to Exempt US-Headquartered Companies