Pillar 2 Newsflash – OECD publications on globe information return

The Global Anti-Base Erosion (“GloBE”) Model Rules contain guidance for a standardized GIR, which contains information that tax administrations need to perform an appropriate tax risk assessment and to evaluate the correctness of a Constituent Entity’s Top-Up Tax liability. The requirement to prepare such a GIR is separate from the complementary payment of taxes under a tax return. The GIR consists of a general section, that applies to the MNE Group as a whole, and multiple jurisdictional sections based on a single template that need to be filled in for every jurisdiction where the MNE Group is operating.

The XML Scheme for exchanges pursuant to the GIR User Guide is separated into logical sections based on the schema and provides information on specific data points and any attributes that describe each data point.