On 11 September 2026, the OECD released an updated GloBE Information Return (GIR) applicable to fiscal years beginning on or after 31 December 2025, introducing structural changes that affect how large multinational groups document and report their Pillar Two positions globally. This update follows the OECD/G20 Inclusive Framework's approval of the Side-by-Side package on 5 January 2026 and the European Commission's confirmation of its application under the EU Minimum Tax Directive (2022/2523) on 12 January 2026. Groups with consolidated revenue of EUR 750 million or more that are already filing – or preparing to file – their first GIRs should assess the impact of the revised form on their existing reporting workflows without delay.
Background: The Side-by-Side Package and Why the GIR Had to Change
The GloBE Information Return is the standardised filing instrument through which in-scope groups disclose the data required to calculate and verify the Qualified Domestic Minimum Top-up Tax (QDMTT) and the Income Inclusion Rule (IIR) across all jurisdictions in which they operate. The original GIR design preceded several significant policy developments, and the September 2026 update is primarily a response to the Side-by-Side package approved by the Inclusive Framework in January 2026.
The Side-by-Side package introduced new simplifications and safe harbours, including the UPE safe harbour and refinements to the treatment of substance-based income exclusions. It also addressed the interaction between Pillar Two and certain substance-based incentives, an area that had created uncertainty in tax structuring for groups with significant physical presence in multiple jurisdictions. Commission Notice C/2026/253 of 12 January 2026 confirmed that EU member states may apply these developments consistently with the Minimum Tax Directive, which in practice means the updated GIR becomes the reference document for filings under EU law going forward.
Groups that have already begun populating data templates based on the prior GIR version should review whether the structural changes in the September 2026 release require adjustments to their data-mapping, computations, or ERP extracts before submission.
Who Is Affected
The Revenue threshold remains unchanged: the updated GIR applies to multinational enterprise (MNE) groups whose consolidated annual revenue equals or exceeds EUR 750 million in at least two of the four fiscal years immediately preceding the relevant fiscal year, in line with the Minimum Tax Directive (EU) 2022/2523 and the underlying OECD Model Rules.
Practically, the groups most immediately affected are those:
- preparing their first GIR for FY2024, where national filing deadlines are still open or recently extended (see the deadlines section below);
- beginning GIR preparation for FY2025, where the updated form is the applicable version given that the relevant fiscal year started on or after 31 December 2025; and
- operating in jurisdictions that have enacted QDMTT legislation and require a local GIR or an equivalent local filing that references the OECD standard.
Groups with significant operations in jurisdictions where national Pillar Two implementation remains pending – or where local rules diverge from the OECD model – face additional tax risk management challenges, as the interaction between the updated GIR and local filing requirements is subject to national rules that have not yet been fully published in several countries.
Key Deadlines at a Glance
The majority of jurisdictions that have enacted Pillar Two legislation set the first GIR deadline for FY2024 at 30 June 2026. Several jurisdictions have granted formal extensions:
- France: extended to 1 September 2026 (announced 8 July 2026).
- Portugal: filing without penalties permitted until 30 September 2026, pursuant to Order 76/2026-XXV of 3 June 2026.
- Belgium: GIR notification deadline extended to 30 September 2026.
For FY2025 and subsequent years, the updated GIR released on 11 September 2026 is the operative version. Filing deadlines for FY2025 returns are subject to national rules and, where not yet confirmed, should be treated as pending until each jurisdiction publishes its own implementation guidance. Groups should track these dates actively; Irish Revenue, for instance, maintains a dedicated Pillar Two key dates page at revenue.ie that is updated as new information becomes available.
If your group operates across multiple EU jurisdictions and you have questions about how the September deadlines interact with your specific filing calendar, our team is available to assist. Please write to info@ferrazwhitmore.com or visit our contacts page.
What Changed in the Updated GIR
The September 2026 release reflects the following principal changes arising from the Side-by-Side package and subsequent Inclusive Framework guidance:
- Side-by-Side safe harbour: new data fields and election mechanics to accommodate the simplified calculation approach for certain constituent entities, reducing the compliance burden for groups that qualify.
- UPE safe harbour: revised treatment at the level of the Ultimate Parent Entity, with specific disclosure requirements for groups that elect this simplification.
- Substance-based incentives: updated guidance on how qualified refundable tax credits and substance-based income exclusions interact, with corresponding changes to the relevant GIR schedules.
- Transitional UTPR safe harbour: refinements consistent with the Inclusive Framework's position following the Side-by-Side package approval.
- Anti-avoidance rules: additional disclosure fields to support jurisdictions' ability to identify structures that may be subject to STTR or UTPR charges, strengthening the information base available during a tax audit.
Groups that rely on treaty protections or operate under specific tax treaty arrangements should also review whether the updated disclosure requirements affect their treaty-claim positions in any constituent entity jurisdiction, given the increased granularity of the GIR's permanent establishment and source-country fields.
Transfer Pricing and GIR Alignment
A recurring compliance risk for in-scope groups is inconsistency between GloBE computations and the transfer pricing positions reported in local country-by-country reports (CbCR) and transfer pricing documentation. The updated GIR introduces additional reconciliation points that auditors in multiple jurisdictions are expected to use as a cross-check. Groups should verify that their Pillar Two effective tax rate computations are consistent with their transfer pricing policies and that any adjustments made for GloBE purposes are properly documented so as to withstand scrutiny in a tax audit.
For groups with operations in Spain, our guide on the Spanish Pillar Two forms 240, 241 and 242 sets out the local filing obligations in detail and may assist groups reconciling their GIR data with Spanish QDMTT returns.
Immediate Action Items for International Companies
Based on the information available as of 22 September 2026, we recommend that in-scope groups consider the following steps:
- Version control: confirm that your GIR data templates and any vendor software reflect the September 2026 release, not the prior version, for all FY2025 and later filings.
- Open FY2024 filings: if your group benefits from a deadline extension in France, Portugal, Belgium, or another jurisdiction, assess whether any aspects of the updated GIR are relevant to your FY2024 submission before the extended deadline expires.
- Side-by-Side eligibility review: evaluate whether your group qualifies for the Side-by-Side or UPE safe harbour elections introduced in January 2026 and reflected in the updated form, as these may materially simplify your compliance position.
- CbCR and TP consistency: run a reconciliation between your Pillar Two computations and existing transfer pricing documentation to identify and address any inconsistencies before filing.
- National implementation monitoring: maintain a jurisdiction-by-jurisdiction tracker of local Pillar Two filing deadlines, penalty regimes, and any local variations from the OECD GIR standard, particularly in jurisdictions where implementation rules remain pending.
Structuring your group's approach to these action items early – rather than in the final weeks before a deadline – reduces the risk of rushed filings and the tax risk management exposure that accompanies them. To discuss your group's specific situation, contact us at info@ferrazwhitmore.com or use our contacts page.
Jurisdictional Context: EU and Beyond
Within the European Union, the Minimum Tax Directive (EU) 2022/2523 provides the binding framework, and Commission Notice C/2026/253 aligns the Side-by-Side package with that framework. Groups operating solely within the EU can therefore rely on a relatively coherent legal basis – though local transposition laws, penalty provisions, and filing portals vary significantly by member state.
Outside the EU, Pillar Two implementation differs considerably. Some jurisdictions have enacted QDMTT legislation that closely follows the OECD model rules; others have not yet legislated or have adopted hybrid approaches. In these cases, the GIR may be filed in the UPE jurisdiction on behalf of the group, but local top-up tax obligations – if any – are governed by national rules that may not yet reference the updated September 2026 GIR. Groups with Eastern European or CIS exposure should note that implementation in those markets is at varying stages; our tax structuring practice for Ukraine and our tax structuring practice for Russia can provide jurisdiction-specific guidance on how Pillar Two obligations interact with local tax regimes.
Sources
- Irish Revenue – Pillar Two key dates: revenue.ie/en/companies-and-charities/pillar-two/dates/index.aspx
- EU Minimum Tax Directive 2022/2523
- Commission Notice C/2026/253 (12 January 2026)
- OECD/G20 Inclusive Framework – Side-by-Side package approval (5 January 2026)
- OECD – Updated GloBE Information Return (11 September 2026)
- Portuguese Order 76/2026-XXV (3 June 2026)
- Facts last verified: 22 September 2026.
For tailored advice on how the updated GIR affects your group's filing obligations, safe harbour eligibility, or transfer pricing alignment, please reach out to the Ferraz & Whitmore international tax team at info@ferrazwhitmore.com or visit our contacts page.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.