On 18 May 2026, the OECD released a package of administrative guidance and implementation support measures under the Pillar Two Global Anti-Base Erosion (GloBE) framework. The measures address practical implementation challenges arising in the first year of GloBE compliance, particularly regarding the filing and exchange of the GloBE Information Return (GIR).
The package focuses on two main areas:
- A common understanding among Inclusive Framework jurisdictions to support centralized filing of the GloBE Information Return (GIR) and provide transitional administrative relief from local filing enforcement and,
- Clarifications on the Transitional Undertaxed Profits Rule (UTPR) Safe Harbor, including a targeted adjustment for 52/53 week fiscal years.
In addition, the OECD updated its Central Record of jurisdictions with Qualified Domestic Minimum Top-Up Taxes (QDMTTs) and safe harbor outcomes.
Under the GloBE framework, in scope multinational enterprise (MNE) groups had been anticipating filing a single GIR in a designated filing jurisdiction, with information exchanged with other relevant jurisdictions through agreed administrative arrangements.
- The GloBE rules require MNE groups to file the GIR within 15 months of the end of the fiscal year and allow 18 months for the first reporting period. Accordingly, calendar-year groups must file the GIR for the 2024 reporting fiscal year by 30 June 2026.The OECD facilitates GIR exchange through two instruments. The OECD drafted the GIR Multilateral Competent Authority Agreement (GIR MCAA)
- The EU administrative framework under Directive on Administrative Cooperation 9 (DAC9), where applicable
In practice, several jurisdictions are at different stages of operational readiness, including the development of GIR/QDMTT/ Qualified Income Inclusion Rule (QIIR) forms, XML schemas, and exchange infrastructure. As a result, exchange relationships are not yet operational in all cases, giving rise to the potential risk of duplicative local filing obligations and administrative uncertainty for the initial compliance cycle.
| OECD common understanding on GIR central filing
|
The OECD has published a jurisdictional common understanding intended to support centralized GIR filing for FY 2024. Under this approach, participating jurisdictions agree, subject to domestic legal constraints, to:
- Accept centralized GIR filing in a participating filing jurisdiction, and
- Support centralized GIR filing by providing relief from local filing enforcement, provided MNE groups meet the relevant notification requirements and file the GIR centrally.
The OECD intends this measure to serve as a transitional administrative solution and not to alter domestic legal filing requirements.
The annex to the OECD support document lists 33 jurisdictions that are expected to be ready for central filing before 31 May 2026, including Australia, Austria, Belgium, Canada, France, Germany, Japan, Korea, the Netherlands, Spain, Switzerland, the United Kingdom and others. The OECD has also noted a specific caveat for Japan. Since Japan's QIIR applies from 1 April 2024, MNE groups can centrally file the GIR in Japan only for fiscal years beginning on or after 1 April 2024.
As of the cut-off date referenced in the OECD materials (12 May 2026), certain jurisdictions had not joined the common understanding, including the Bahamas, North Macedonia, the Slovak Republic, and Vietnam. Greece and Poland participate in the arrangement only in relation to EU Member States included in the annex, potentially limiting the effectiveness of central filing where the filing jurisdiction is outside that scope.
| Updates to OECD Central Record (QDMTT and safe harbor)
|
The OECD has also updated its Central Record of jurisdictions with QDMTT regimes and transitional safe harbor outcomes.
The update includes recognition of additional jurisdictions with qualifying QDMTT regimes and safe harbor status under the transitional framework, expanding the list of jurisdictions included in the OECD’s published record. The Bahamas (with effect from 1 January 2024) and Kenya, Kuwait, and Oman (with effect from 1 January 2025), have each been added to the list of jurisdictions with a QDMTT.
This Central Record is relevant for determining the application of the QDMTT safe harbor and related transitional rules under Pillar Two.
| Transitional UTPR Safe Harbor (52/53 week fiscal years)
|
The OECD also addressed an unintended timing gap affecting MNE groups with 52/53 week fiscal years.
Under the initial framework:
- The Transitional UTPR Safe Harbor applied to fiscal years beginning on or before 31 December 2025 and ending before 31 December 2026, while
- The later safe harbor framework (including Side-by-Side and UPE safe harbor) applies to fiscal years beginning on or after 1 January 2026.
MNEs with a standard 12-month fiscal year will be able to rely on the Transitional UTPR Safe Harbor for FY20225 and then access the SbS or UPE regime for F0Y26. However. This created a potential gap for certain MNEs with 53-week fiscal years beginning in 2025 but extending beyond 31 December 2026, where neither regime would have applied. To address this, the OECD has clarified that the Transitional UTPR Safe Harbor will include fiscal Years that run no longer, than 12 months that begin on or before 31 December 2025 and end on or before 3 January 2027.
