Hong Kong's Inland Revenue Department released revised guidance on the GloBE Information Return, including new XML schema specifications and supplementary user guides, allowing multinational enterprise groups to prepare and validate test data files before submitting compliance filings for the global minimum tax.

RF Report

The Hong Kong Inland Revenue Department (IRD) has revised its guidance on the global minimum tax and Hong Kong minimum top-up tax for multinational enterprise groups, including the release of the GloBE Information Return (GIR) XML Schema and user guides.  It also allows Part 4AA entities—MNE group members within the scope of Hong Kong’s global minimum tax rules—to prepare and submit GIR data files for testing purposes.

GIR XML Schema and user guides 

A GIR must be made in the form of an XML document.  In addition to the GIR XML Schema and user guide published by the OECD, the Department has published a supplementary user guide for preparing a GIR for the Department.

A Part 4AA entity should prepare the GIR in accordance with the XML Schema and the user guides set out below:

GIR XML Schema (Published by OECD in January 2025)

GIR XML Schema User Guide (Published by OECD in January 2025) 

The Schema for exchanges pursuant to the GIR User Guide is divided into logical sections based on the schema and provides information on specific data elements and any attributes that describe each data element.

The main sections of the GIR Schema User Guide are:

  1. The Message Header with the sender, recipient, message type and Reporting Fiscal Year;
  2. The ID and TIN types, used for providing identifying and TIN information in relation to CEs, JVs, JV Subsidiaries and UPEs.
  3. The GloBE Body, which contains five sub-sections –
    • Filing Info, which corresponds to Sections 1.1 and 1.2 of the GIR and contains information identifying the Filing CE and MNE Group;
    • General Section (NB the scope of the term is limited in comparison with the definition under the GIR MCAA), which corresponds to Section 1.3 of the GIR and contains information on the corporate structure of the MNE Group;
    • Summary, which corresponds to Section 1.4 of the GIR and contains the high-level summary of GloBE information;
    • Jurisdiction Section, which corresponds to Sections 2 and 3 (excluding Sections 3.4.3) of the GIR and contains information on the relevant safe harbours and exclusions, ETR computations; Top-up Tax computations where necessary, and finally the allocation of Top-up Tax, if any;
    • UTPR Attribution, which corresponds to Section 3.4.3 of the GIR and contains information on the attribution of Top-Up Tax amongst relevant jurisdictions in case the UTPR is applicable.

The GIR XML Schema is designed to be used for the exchange of information reported under the GIR between competent authorities that have activated exchange relationships under the GIR MCAA, or another Qualifying Competent Authority Agreement.

Where appropriate, jurisdictions could also consider using the schema domestically for the purpose of gathering the required information from their respective Filing CEs.

The requirement field for each data element and its attribute indicate whether the element is validation or optional in the schema. Every element is one or the other in the schema.

There may be different business rules for elements that are optional in the schema:

  • Some optional fields are shown as “Optional (Mandatory)” – an optional element that is required to be completed whenever the GloBE Model Rules require its completion. Mandatory elements may be present in most (but not all) circumstances, so there cannot be a simple IT validation process to check these. For instance, the IntShippingIncome element must only be completed in cases where the International Shipping Income exclusion applies (i.e. when the MNE Group has International Shipping Income).
  • Optional elements may be provided, but are not required to be completed.

Supplementary User Guide for Preparing GIR

From now on, Part 4AA Entity can prepare test data file of GIR and submit it to the Pillar Two Portal for validation testing purpose.

This supplementary User Guide facilitates a Part 4AA entity of an in-scope MNE group to prepare the information required in the standardised GloBE Information Return (GIR). It explains what information needs to be included in some data elements to be reported to the Inland Revenue Department (IRD) in the GIR. 2. It should be read in conjunction with the GIR XML Schema User Guide issued by the Organisation for Economic Co-operation and Development (OECD), which specifying the data structure and format for reporting the GIR.

Validation process 

  1. The data files uploaded into the Pillar Two Portal will go through validation checking. Filing Entity will be informed of the validation result by an e-message sent to its Message Box in the Business Tax Portal. If errors are identified, a list will be given for the Filing Entity to locate the relevant section in the XML file that contains error.
  2. The validation is a two-stage process:
    • Schema Validation – File Structure: The XML file is checked to ensure its structure is correct and complete.
    • Database Validation – Logical Checks: The data contained in the XML file are checked for logical consistency. For example, for correction of data, the system will check if a corresponding data record exists in the corresponding Pillar Two Portal account.
  1. Some examples of errors within the XML message are provided at Appendix A for reference.
  2. The top-up tax return will not be regarded as valid if the data file attached to it is subsequently found not conforming to the GIR XML Schema and the user guides specification

Submission of Test Data File for testing

  1. Filing Entity can develop its own computer program for preparing the GIR. Before implementing its own program, the Filing Entity can upload a test data file into the Pillar Two Portal to verify whether the GIR produced by its program conforms to the specifications in the GIR XML Schema. Filing Entity has to state in the Document Type Indicator that it contains test data only. The codes OECD10 through OECD13 are allowable entries. Please refer to the guidance set out in the Corrections section of the GIR XML Schema User Guide on page 126 for more description of this indicator.