New Zealand Inland Revenue updated its guidance on 9 September 2026 on the application of the Pillar Two GloBE Rules, including requirements for registration, notifications, GloBE information return (GIR) filing and top-up tax returns. The guidance also covered changes adopted under the Side-by-Side (SbS) Package.
New Zealand Inland Revenue updated its guidance on 9 September 2026 on the application of the Pillar Two GloBE Rules to multinational enterprise (MNE) groups with a constituent entity in New Zealand.
The GloBE rules apply to MNE groups with global annual revenue exceeding EUR 750 million in at least two of the previous four years where the group has a constituent entity in New Zealand. The rules apply to fiscal years beginning on or after 1 January 2025.
The ultimate parent entity’s (UPE) fiscal year end determines the deadlines for GloBE registration and other filing requirements.
GloBE registration
A designated New Zealand constituent entity must register a GloBE account for the MNE group within six months of the end of the first fiscal year to which the GloBE rules apply.
Only one registration is required for each MNE group, covering all its constituent entities in New Zealand. The designated New Zealand constituent entity must identify all New Zealand constituent entities as part of the registration.
For example, an MNE group with a fiscal year ending on 31 December 2025 must register by 30 June 2026. For a 31 March 2026 year end, the deadline is 30 September 2026, while an MNE with a 30 June 2026 year end must register by 31 December 2026.
Registration is required even where an MNE group is within the scope of the rules for only part of a fiscal year, including where it is disposing of or dissolving its New Zealand operations.
Joint ventures accounted for under the equity method in an MNE group’s consolidated financial statements should not be included as constituent entities in the registration. Their details will instead be provided in the GloBE information return (GIR).
Joint ventures consolidated on a line-by-line basis should be included in the registration. A New Zealand permanent establishment of an entity included in the MNE group’s consolidated financial statements on a line-by-line basis is also treated as a separate constituent entity for registration purposes.
Failure to register or provide an accurate notification could result in a penalty of up to NZD 100,000.
Side-by-Side Package
New Zealand has adopted changes to the GloBE rules under the Side-by-Side (SbS) Package published by the OECD on 5 January 2026.
The Simplified ETR Safe Harbour and Substance-based Tax Incentive Safe Harbour are available for fiscal years commencing on or after 1 January 2026.
The Transitional CbCR Safe Harbour has been extended for an additional year. It covers fiscal years beginning on or before 31 December 2027, but does not apply to a fiscal year ending after 30 June 2029.
The Side-by-Side Safe Harbour and UPE Safe Harbour are available for fiscal years beginning on or after 1 January 2026 for MNEs with a fixed-date fiscal year end, such as 31 December.
For MNEs using a 52- or 53-week fiscal year ending on the same day of the week each year, the safe harbours are available for fiscal years starting on or after 26 December 2025.
GloBE notifications and information returns
As part of registration, the designated constituent entity provides information covering all New Zealand constituent entities of the MNE group. This information forms part of a standing notification.
Changes to the notification must be made within six months of the end of the fiscal year. These changes can include the fiscal year end, GloBE Information Return (GIR) filing responsibility and GIR filer details.
MNE groups can also update information about the UPE and New Zealand constituent entities, including adding, editing or removing records.
If the designated New Zealand constituent entity changes, the existing entity must de-register and the new designated New Zealand constituent entity must register.
For New Zealand-headquartered MNEs, the GIR will be filed in New Zealand by the designated New Zealand constituent entity. For MNEs headquartered outside New Zealand, the GIR may be filed in New Zealand or overseas by a constituent entity in another implementing jurisdiction that will exchange the return with New Zealand.
The GIR can be filed in New Zealand 18 months after the end of the first fiscal year to which New Zealand’s GloBE rules apply. New Zealand-headquartered MNEs may need to file within 15 months of the first applicable fiscal year where they are already subject to GloBE rules in other jurisdictions.
The GIR must be submitted electronically through myIR in XML format meeting the requirements of the OECD GIR XML Schema. Information exchanged between jurisdictions will depend on the MNE group’s structure and how the GloBE rules apply in each jurisdiction, including the income inclusion rule (IIR), undertaxed payments rule (UTPR) and qualified domestic minimum top-up tax (QDMTT).
Top-up tax returns
The designated New Zealand constituent entity will be required to file the multinational top-up tax return through myIR. The online return is expected to become available from April 2027.
The return will require the relevant fiscal year end, the conversion rate used between the GIR and top-up tax return, and the amount of top-up tax payable, split between IIR, DIIR and UTPR. All top-up tax amounts must be reported in New Zealand dollars.
IIR and UTPR top-up taxes apply for fiscal years beginning on or after 1 January 2025, while DIIR top-up tax applies for fiscal years beginning on or after 1 January 2026.
For the first fiscal year to which the rules apply, the top-up tax return will be due 20 months after the fiscal year end. For subsequent years, the deadline will be 16 months after the fiscal year ends.
Proposed remedial legislation
Inland Revenue also outlined proposed remedial legislation affecting top-up tax return filing.
The proposals would provide for a single top-up tax return by the designated constituent entity covering all New Zealand constituent entities. They would also remove the requirement to file a top-up tax return where there is no top-up tax liability and clarify how the time bar applies.
The updated guidance has therefore set out the current registration, notification and filing framework for MNE groups within the scope of New Zealand’s GloBE rules, together with the applicable deadlines and proposed changes to the top-up tax return process.
