As of the OECD update of 26 August 2025, the GIR MCAA has been signed by 15 jurisdictions.
The Netherlands has signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA), under Pillar Two of the OECD/G20 Inclusive Framework’s Two-Pillar Solution on 14 August 2025.
As of the OECD update of 26 August 2025, the GIR MCAA has been signed by 15 jurisdictions.
The Global Anti-Base Erosion (GloBE) Model Rules require each Constituent Entity of an MNE Group to annually file a GloBE Information Return (GIR) with the tax administration of the jurisdiction where it is located to support the administration of the GloBE Rules.
The GIR is a standardised return and consists of two parts, namely a General Section that provides general information about the MNE Group as a whole, including its corporate structure and a high-level overview of the application of the GloBE Rules to the MNE Group, as well as one or more Jurisdictional Sections reflecting the detailed application of the GloBE Rules and the QDMTT, where applicable, in respect of each jurisdiction where the MNE Group operates.
A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a plan to update key elements of the international tax system, which is no longer fit for purpose in a globalised and digitalised economy.
The Global Anti-Base Erosion Rules (GloBE) are a key component of this plan, ensuring that large multinational enterprises pay a minimum level of tax on the income arising in each of the jurisdictions where they operate.
