The revised GIR incorporates the January 2026 side-by-side safe harbours, allowing US-headquartered companies to avoid certain foreign Pillar Two reporting obligations while preserving US tax rules and benefits.
The US Treasury has welcomed the OECD/G20 Inclusive Framework’s release of the revised GloBE Information Return (GIR) on 11 September 2026. The changes implement President Trump’s directive to exempt American corporations from the international tax agreement negotiated by the previous administration.
The revised GIR forms part of a broader Pillar Two package and incorporates simplifications agreed under the Side-by-Side package in January 2026.
On 5 January 2026, the OECD announced that the 147 members of the OECD/G20 Inclusive Framework on BEPS had agreed on key elements of a side-by-side arrangement, including two safe harbours for multinational enterprise groups headquartered in jurisdictions with an eligible tax regime.
Treasury Secretary Scott Bessent stated that the new framework protects American tax authority and reduces paperwork for US-headquartered companies. The revised Global Minimum Tax (GloBE) Information Return allows companies to opt out of overlapping foreign tax rules while remaining subject to US minimum tax requirements.
What changed
The original GloBE Information Return, released in January 2025, would have required American companies to report financial details for operations in every country where they do business. This served the OECD Pillar Two framework, a global minimum tax deal from 145 countries in the OECD and G20 group.
In January 2026, the Treasury negotiated a separate agreement with these countries. Under this “side-by-side” arrangement, US companies can skip the foreign reporting required by Pillar Two rules. They remain subject only to American tax law instead.
How it works
The revised return lets American companies elect the side-by-side safe harbour. This exemption removes two specific Pillar Two obligations: the Income Inclusion Rule and the Undertaxed Profits Rule.
The new framework also protects valuable American tax benefits. Companies can apply the Research and Development tax credit without facing Pillar Two adjustments. Foreign companies operating in the US receive the same R&D credit protection.
The revised return serves as a standardised reporting tool for local minimum taxes in other countries. Information companies provide for one country’s tax rules stays within that country and is not shared internationally.
Next steps
The Treasury indicated that countries are adopting the side-by-side safe harbour through their own legislative processes. The department plans to continue coordinating with international partners as the framework is implemented.
