Belgium is among 33 implementing countries that agreed on 18 May 2026 to accept centralised filing of the GloBE Information Return, allowing multinational enterprises to submit reports through a single jurisdiction provided they notify Belgium and the exchange occurs by 31 December 2026, with penalties waived during the transition period.
The OECD released the common understanding of implementing jurisdictions on the centralised filing and exchange of the GloBE Information Return (GIR) on 18 May 2026. 33 of the 37 implementing countries, which impose a reporting obligation from the 2024 financial year and for which multinational enterprise groups (MNE groups) must submit their GloBE Information Report (GIR) by 30 June 2026, have stated that they would accept a central GIR filing, provided that it is exchanged by 31 December 2026.
To enable this exchange, countries must sign and activate the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (MCAA GIR). It is expected that some countries will not be able to activate the MCAA GIR before 30 June 2026, but will do so before the exchange deadline of 31 December 2026.
The countries concerned, including Belgium, on 8 June 2026, have agreed to apply these obligations flexibly: they will not impose fines and will not impose a local filing obligation, provided that the GIR is filed centrally in another implementing jurisdiction and that this is notified in a timely manner via the GIR notification.
If, ultimately, the centralised filing is not transmitted to a country within the allotted time, that country reserves the right to take action and require a local filing. Should Belgium require a local filing, it will communicate this in a timely manner and set a deadline for the filing. Belgium will not impose any penalties if the filing is completed before this deadline.
The annex to the Common Position contains the list of countries * that should be ready for central filing for the 2024 financial year.
This principle also applies to EU member states that have not transposed the DAC9 directive within the allotted time.
Earlier, on 18 May 2026, the OECD issued administrative guidance to assist multinational groups in meeting the Pillar Two GloBE Information Return (GIR) filing requirements ahead of the 30 June 2026 deadline. Under a common understanding agreed by 2024 implementing jurisdictions, penalties will be waived and local filing obligations suspended where a group centrally files its GIR in a jurisdiction included on the published list within the applicable deadline. This applies provided a GIR notification is also submitted in the local jurisdiction within the required timeframe.
