The OECD has released an updated common understanding on the central filing of Pillar Two GloBE Information Returns (GIRs), providing relief from local filing penalties for jurisdictions implementing the global minimum tax, subject to specific filing, notification, and exchange requirements.
The OECD has published a revised version of the common understanding on Pillar Two GloBE Information Return (GIR) filing on 25 June 2026.
The first version of the common understanding on Pillar Two GIR filing was released on 18 May 2026, titled, Global Minimum Tax: Support for Central GloBE Information Return Filing and Exchange (2024 Reporting Fiscal Year).
The common understanding stipulates that jurisdictions implementing the Global Minimum Tax from 2024 have agreed to waive penalties or defer enforcement of local GIR filing obligations, provided that the GIR has been centrally filed in a jurisdiction included in the published list by the relevant filing deadline and that a GIR notification has been submitted in the local jurisdiction within the applicable timeframe.
A “common understanding” has been agreed among jurisdictions implementing Pillar Two and published by the OECD to facilitate the central filing of 2024 year-end GIRs.
The agreement includes an annex identifying 33 jurisdictions expected to have fully operational GIR portals available for central filing by 31 May 2026, including Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Czech Republic, 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, Turkey, and the UK.
The common understanding provides that implementing jurisdictions will waive penalties and refrain from enforcing local GloBE Information Return (GIR) filing requirements, provided that the GIR is submitted by the applicable deadline in a jurisdiction included in the annex, notification of the filing is submitted, and the GIR is exchanged by the required deadline (31 December 2026 for the first year).
In some cases, such as Poland, this relief applies only to GIR filings made in other EU Member States. The updated version also confirms the inclusion of the Bahamas and Greece, while the Slovak Republic has joined the arrangement for all jurisdictions listed in the annex, except those without an active exchange relationship with the Slovak Republic.
