The OECD has released Version 2.0 of the Pillar Two GloBE Information Return XML Schema, incorporating Side-by-Side Package changes and technical updates, with mandatory use for international exchanges from June 2028.
The OECD published an updated user guide and XML schema for the Pillar Two GloBE Information Return (GIR) on 20 October 2026. Version 2.0 reflects recent changes to the GIR made after the adoption of the Side-by-Side Package. It also includes technical upgrades to support future information exchanges.
This documentation provides technical standards and instructions for tax administrations and multinational enterprise groups regarding the automatic exchange and domestic filing of tax calculation data. It details the schema’s structural hierarchy, which encompasses message headers, entity identification categories, corporate structure summaries, and top-up tax allocations.
Purpose and regulatory context
The Global Anti-Base Erosion (GloBE) Model Rules under Pillar Two require Multinational Enterprise (MNE) Groups to file an annual GloBE Information Return (GIR) detailing their top-up tax calculations under the Global Minimum Tax regime. To establish a consistent technical standard across implementing jurisdictions, the OECD/G20 Inclusive Framework on BEPS developed the GIR XML Schema and User Guide.
The primary objective of the XML schema is to facilitate the Automatic Exchange of Information (AEOI) between tax administrations under bilateral or multilateral agreements, such as the GloBE Multilateral Competent Authority Agreement (GIR MCAA).
2026 revisions and evolution of the schema
The GIR XML schema has progressed through multiple key updates to keep pace with evolving guidance:
- July 2023: Agreement by the Inclusive Framework on a standardised GIR template.
- 15 January 2025 (Version 1.0): Updated to incorporate technical clarifications, administrative guidance from December 2023 and June 2024, and exchange notification templates.
- 11 September 2026: Revised to integrate the Side-by-Side Package (adopted on 5 January 2026) alongside further technical refinements.
- 14 October 2026 (Version 2.0): Formally approved by the Inclusive Framework on BEPS as the updated October 2026 User Guide for Schema Version 2.0.
Implementation timeline & version transition
The User Guide sets two schema versions with a hard handover:
- Version 1.0, released in January 2025, governs standard GIR exchanges during the initial rollout and stays in use until 15 June 2028.
- Version 2.0, released this month (October 2026), takes over from 25 June 2028 for all exchanges.
The catch is that 2.0 also applies to amendments and corrections of returns first exchanged under 1.0, so a late correction to an early filing will have to be submitted in the newer format.
International exchange vs. domestic filing
The XML schema supports both international exchange of GIR filings under a Central Filing Framework (GIR401/GIR402) and domestic reporting under a Local Filing Framework (GIR403–GIR405), with local filings excluded from international exchange.
Structural architecture of the schema
The GIR XML schema is split into three layers: a header, a set of shared identifier types, and the GloBE body where the real content sits.
The message header carries the routing and filing metadata: which tax authorities are sending and receiving, when the message was created, the Reporting Fiscal Year, and whether the report is original, corrected, or nil. The ID and TIN types standardise how entities are identified. They cover Tax Identification Numbers for Constituent Entities, Joint Ventures, JV Subsidiaries, and Ultimate Parent Entities, so every later section refers to the same entities in the same way.
The GloBE body has five sub-sections, which run from broad to granular:
- Filing Info covers group reporting arrangements, corporate changes, accounting standards, and filing frameworks.
- The General Section maps the MNE Group’s corporate hierarchy and names the recipient jurisdictions.
- Summary gives the high-level picture per jurisdiction: how the GloBE rules apply, ETR ranges, safe harbour status, and top-up tax figures.
- Jurisdiction Section is the detailed layer, with ETR calculations, covered tax adjustments, safe harbour elections, and top-up tax allocations, one jurisdiction at a time.
- UTPR Attribution calculates how top-up tax under the Undertaxed Profits Rule is allocated across the participating jurisdictions.
