The OECD has introduced relief measures for multinational corporations filing Global Minimum Tax returns, allowing central filing in any of 33 operationally ready jurisdictions while waiving local penalties if deadlines are met. The guidance, published on 18 May 2026, addresses coordination challenges ahead of the 30 June 2026 filing deadline and updates qualification records to include four new jurisdictions implementing the 15% minimum tax framework.
The OECD has released crucial administrative guidance to help multinational corporations navigate the complex filing requirements of the Pillar Two Global Minimum Tax, addressing concerns about meeting the upcoming 30 June 2026 deadline.
Under the new common understanding published on 18 May 2026, jurisdictions implementing the Global Minimum Tax from 2024 have agreed to provide relief for companies facing potential delays in portal availability.
The common understanding provides that jurisdictions applying the Global Minimum Tax from 2024 have agreed to waive penalties or suspend enforcement of local GIR filing requirements where the GIR has been centrally filed in any jurisdiction included in the published list by the applicable filing deadline, and where a GIR notification has been submitted in the local jurisdiction by the relevant deadline.
However, this flexibility comes with conditions. If the centrally filed GIR is not properly exchanged between tax authorities by 31 December 2026, jurisdictions may enforce local filing requirements and potentially impose penalties. This safeguard ensures that tax authorities receive the necessary information despite the transitional arrangements.
A “common understanding” has been reached among Pillar Two implementing jurisdictions and published by the OECD to support central filing for 2024 year-end GIRs. It includes an annex listing 33 jurisdictions expected to have a fully operational GIR portal in place for central filing by 31 May 2026: Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Czechia, Denmark, Finland, France, Germany, Gibraltar, Greece, Hungary, Ireland, Italy, Japan, Korea, Liechtenstein, Luxembourg, the Netherlands, Norway, Poland, Portugal, Romania, Slovenia, South Africa, Spain, Sweden, Switzerland, Türkiye, and the United Kingdom.
It is noted that Japan has a Qualified IIR applying from 1 April 2024, and MNE groups will only be able to centrally file the GIR in Japan for fiscal years beginning on or after that date. Greece and Poland have joined the common understanding only in respect of other EU Member States included in the list. The Bahamas, North Macedonia, the Slovak Republic, and Vietnam have not joined the common understanding as of 12 May 2026.
Scope and application of the rules
The Pillar Two framework targets large multinational enterprises with annual consolidated group revenue of at least 750 million euros. These rules aim to establish a 15% minimum effective tax rate across all jurisdictions where these groups operate, generating top-up taxes when local rates fall below this threshold.
Key components of the global minimum tax
The system operates through three main mechanisms. Qualified Domestic Minimum Top-up Taxes allow countries to collect top-up taxes on profits earned within their borders. The Income Inclusion Rule enables parent company jurisdictions to apply top-up taxes on a cascading basis throughout the corporate structure. Starting from 2025, the Undertaxed Profits Rule serves as a backstop mechanism when other rules have not been fully implemented.
The OECD also updated its central record to include four additional jurisdictions whose legislation meets the qualification standards, while providing further clarity on the transitional UTPR safe harbour provisions to support consistent implementation across participating countries.
Common understanding of jurisdictions implementing the Global Minimum Tax in 2024
Multinational Enterprise (MNE) Groups in scope of the GMT are relieved from locally filing a GIR in each jurisdiction where they operate, where such GIR is centrally filed in the jurisdiction of the Ultimate Parent Entity or a Designated Filing Entity, appropriate notifications have been filed, and the central filing jurisdiction shares the relevant GIR information with the local jurisdictions under the agreed Exchange of Information framework.
The central record of Qualified Income Inclusion Rules (QIIR) and Qualified Domestic Minimum Top-up Taxes (QDMTT) shows that 37 jurisdictions have implemented a QIIR and/or a QDMTT that applies to in-scope MNE Groups as of their 2024 reporting fiscal year. As the due date for the first GIR filings approaches, almost all jurisdictions are expected to have a fully operational portal in place for MNE Groups to timely file the GIR, however some may only be able to formally activate exchange relationships after the relevant filing deadline (and still in time for the exchanges to take place before the end of the year).
To address the compliance and co-ordination challenges that could arise in respect of the delays in the activation of exchange relationships, the common understanding reflects an agreement among jurisdictions implementing the GMT from 2024 to apply mechanisms, to the extent available under their respective domestic laws, in order to avoid adverse consequences for taxpayers, and waive penalties or not enforce their local GIR filing obligation when the GIR has been centrally filed in one of the jurisdictions that are operationally ready to support central filing. Thus, in-scope MNE Groups would not be negatively affected merely because an exchange relationship is not fully activated by the filing deadline.
Updates to the central record for purposes of the global minimum tax
The Central Record for Purposes of the Global Minimum Tax sets out those jurisdictions whose minimum tax legislation has completed the process for the transitional qualification mechanism and will be considered as qualified for purposes of the rule order. The central record has been updated to reflect that the Bahamas, Kenya, Kuwait and Oman have completed the transitional qualification mechanism with respect to their DMTTs. As a result, the central record now shows that 44 jurisdictions have completed the process for their IIR, and 50 jurisdictions completed the process for their DMTT and QDMTT Safe Harbour.
Administrative guidance on the application of the Transitional UTPR Safe Harbour
The OECD/G20 Inclusive Framework on BEPS has released new administrative guidance that addresses an unintended gap that arose in instances where an MNE Group with a 53-week fiscal year has its UPE located in a jurisdiction that is eligible both for the Transitional UTPR Safe Harbour, and then for the Side-by-Side (SbS) Safe Harbour or the UPE Safe Harbour for fiscal years starting on or after 1 January 2026. The guidance clarifies that such MNE Group will remain eligible for the Transitional UTPR Safe Harbour until the SbS Safe Harbour or UPE Safe Harbour applies.
