What the July 2023 GIR contains
The OECD GloBE Information Return (GIR), approved on 13 July 2023, standardises the information used to assess an MNE group’s global minimum tax calculations. Its 82 pages contain the introductory reporting and dissemination framework, the complete return template in Annex A1 and field-by-field explanations in Annex A2. The GIR is an information return, distinct from a domestic tax return or payment obligation. This article explains the original 2023 edition, including its transitional provisions, rather than presenting the template as the latest filing specification. This is an adaptation of an original work by the OECD. The opinions expressed and arguments employed in this adaptation should not be reported as representing the official views of the OECD or of its Member countries.
Three connected parts of the return
Part 1 identifies the filing entity, group, consolidated accounts, ultimate parent and corporate structure, followed by a high-level summary for every relevant jurisdiction and separate calculation perimeter. Part 2 documents safe harbours, de minimis exclusions and the initial phase of international activity. Part 3 reconciles accounting income and tax to GloBE amounts, records deferred taxes and elections, calculates top-up tax and allocates it under the IIR and UTPR. Jurisdictions without implementing rules can still appear because their group entities affect calculations and taxing rights elsewhere.
Central filing and local filing are linked to exchange arrangements
A constituent entity ordinarily files locally unless the ultimate parent or a designated filing entity files in a jurisdiction with a qualifying competent authority agreement in effect with the local jurisdiction by the deadline. The filing location and entity must be identified. A jurisdiction receiving local filing should obtain the same relevant information that it would receive through exchange. The document distinguishes supplementary domestic administration fields, such as liability, payment timing, currency, identification and contact details, from duplicating the complete GloBE computation. In this edition, XML and exchange implementation frameworks were still being developed.
Who receives which information
The implementing ultimate-parent jurisdiction receives the complete GIR. Implementing jurisdictions containing constituent entities receive general group and structure information and the global high-level summary. A jurisdiction with qualified-rule taxing rights receives the detailed safe-harbour, effective-tax-rate, top-up-tax and allocation information for the jurisdictions or subgroups over which those rights extend. Rights follow the rule order even if no tax is ultimately payable, for example because an ETR is above 15%; both an ultimate-parent and partially-owned-parent jurisdiction may have relevant IIR rights. The group identifies recipients and may choose to send the full return to all implementing jurisdictions containing its entities.
High-level tax summaries use bands rather than exact figures
For each jurisdiction and separate subgroup, the summary identifies taxing-right jurisdictions, the applied safe harbour or de minimis exclusion, the ETR band and whether the substance-based income exclusion eliminates top-up tax. ETR bands run in 2.5-percentage-point increments from below 2.5% to 30% or above. QDMTT and GloBE top-up tax are reported separately in bands: zero; below EUR 1 million; EUR 1–5 million; EUR 5–25 million; EUR 25–50 million; EUR 50–75 million; EUR 75–100 million; EUR 100–250 million; or EUR 250 million and above, with each interval’s upper endpoint excluded. SBIE is marked not applicable where it is not calculated.
What transitional simplified reporting does and does not waive
The 2023 framework can be elected for fiscal years beginning on or before 31 December 2028 and ending on or before 30 June 2030. It permits jurisdiction-level reporting of certain adjustments where there is no top-up tax or no need for entity-level allocation. It does not waive the entity calculations underlying the jurisdictional result. If entity allocation is needed, the relevant entity additions and reductions must be separately reported; otherwise specified adjustments can be reported as net additions or reductions. Certain cross-border, election, shipping, joining/leaving and transition disclosures remain compulsory. A QDMTT safe-harbour jurisdiction can decline to allow this framework.
Keep calculation and allocation evidence
Simplified filing relies on contemporaneous records that establish where each entity is located, how financial income and taxes are allocated and how calculations reconcile to consolidated accounts. Records must identify the items included in each reported adjustment and support allocations of top-up tax. The document does not prescribe one mandatory working-paper format. Tax administrations can request supporting entity information during risk assessment or follow-up review. Prospective permanent simplifications and coordinated enquiries discussed in the introduction were further work, not blanket exemptions already granted by this edition.
Identify the filer, reporting year and accounting basis
The return records the filing entity’s name, tax identification number, role, location and exchange recipients. When the filer is the ultimate parent, the dedicated UPE fields replace the duplicate filer fields. A functional equivalent, such as a company registration number, can be used where no TIN exists. Group information includes the commonly used consolidated group name, fiscal-year beginning and end, amendment flag, consolidated-statement type, accounting standard and ISO currency. For deemed consolidation, the standard is determined reasonably and in good faith with due diligence. Countries use ISO alpha-2 codes; stateless entities are identified separately.
Map the ultimate parent and each constituent or JV entity
The UPE record identifies its jurisdiction, applicable qualified IIR, UTPR and QDMTT rules, name, TIN, filing jurisdiction and GloBE status. An excluded UPE does not complete the jurisdiction/rule fields specified by the notes. The year-end structure lists constituent entities, JVs and JV subsidiaries, their jurisdiction, tax and local identifiers, status and ownership. Several statuses can apply together, including permanent establishment, main entity, tax-transparent or reverse-hybrid flow-through entity, hybrid, minority-owned entity and investment entity. If prior-year information remains valid and complete, the change flag permits designated fields to be omitted; a change requires the full relevant entity list, not only the changed rows.
Ownership reporting prevents double counting
Owners are identified as UPEs, constituent entities, JV entities, excluded entities or non-group holders. Excluded entities other than the UPE and non-group owners are aggregated, without the TIN required for individually identified group owners. Indirect group ownership through an excluded or non-group holder is added to the appropriate group owner’s direct interest, while the corresponding intermediate aggregate interest is reduced to avoid counting the same interest twice. A permanent establishment identifies its main entity and 100% ownership. IPE and POPE fields apply only where qualified-IIR parent status is relevant; a POPE involves more than 20% of profit ownership held by non-constituent owners.
Parent exceptions, excluded entities and structural changes
The return identifies the higher parent that removes an IPE’s IIR obligation under Article 2.1.3 or a wholly owning POPE under Article 2.1.5. It records aggregate qualified-IIR ownership or JV allocable shares where relevant, counting overlapping interests only once, and compares them with the UPE interest. Excluded entities are listed by name and category, including government, international, nonprofit and pension bodies, qualifying UPE funds or real-estate vehicles and Article 1.5.2 entities. Structural-change rows report each effective date, before/after status and ownership when the change affects ETR, computation or tax allocation. Changes with no such effect are flagged separately rather than inserted into the detailed table.
Identify every separate calculation perimeter
A jurisdiction can contain ordinary constituent entities, minority-owned subgroups, standalone minority-owned entities, investment entities, JV groups or stateless entities requiring separate ETR or top-up-tax computations. The return identifies the type and the TIN of the entity at the top of each subgroup. Investment entities include qualifying investment JVs, but not entities brought into transparent treatment by an Article 7.5 election. The safe-harbour section also identifies the group covered by transitional CbCR treatment. A single country total must not obscure separate blending perimeters.
Report the safe-harbour election and its remaining obligations
The template distinguishes permanent de minimis, ETR and routine-profit tests; QDMTT safe harbour; transitional CbCR de minimis, simplified-ETR and routine-profit tests; and transitional UTPR relief for the UPE jurisdiction. Where more than one test qualifies, the group selects its test. The transitional CbCR election cannot be restarted after a prior-year failure to use it under the notes. QDMTT safe-harbour reporting still requires the relevant domestic calculations in Part 3, and cannot be elected if its switch-off rule applies. Partial simplified calculations require the remaining computation sections; permanent safe harbours still require additional-current-top-up disclosures, and routine-profit tests require SBIE information.
Substantiate non-material-entity and transitional CbCR tests
For simplified non-material-entity calculations, report total revenue for the current and two preceding years and its average; the ETR test also requires current simplified tax. Transitional CbCR fields record qualified-report revenue, profit or loss before tax and, for the ETR test, simplified covered taxes. Held-for-sale entity revenue must be considered: the de minimis option is unavailable where adding it to jurisdictional CbCR revenue reaches EUR 10 million. Separate financial statements using a different standard trigger the other-accounting-standard disclosure. Transitional UTPR reporting records the UPE jurisdiction’s corporate rate.
De minimis exclusion retains specific computations
Investment and stateless entities are not eligible, and their GloBE revenue and income are excluded from the relevant jurisdictional averages. Minority-owned entities remain included in the de minimis averages. Report accounting revenue, GloBE revenue, accounting net income and GloBE income for the current year and two preceding years, together with averages adjusted for non-calendar-length periods where required. An elected exclusion still requires the other-accounting-standard fields when applicable and the additional-current-top-up-tax section. It therefore does not eliminate every Part 3 field.
Initial international activity is a UTPR-specific exclusion
The return identifies the first in-scope fiscal year, reference jurisdiction, initial tangible-asset values and jurisdictions, then current jurisdiction count and non-reference asset total. Article 9.3 relief lasts no more than the specified five-year window; for a group already in scope when the rules commence, the starting point is when the UTPR comes into effect. Up to five jurisdictions other than the reference jurisdiction are reported. JV, JV subsidiary and non-excluded investment-entity locations and assets are disregarded for these tests. Stateless assets are outside the reference jurisdiction unless their physical presence there is demonstrated. When no group entity applies a qualified IIR, the notes allow omission of the other jurisdictional computation sections covered by this UTPR exclusion.
Reconcile financial income to net GloBE income
The jurisdictional table starts from accounting net income after permanent-establishment and flow-through allocations, then reports the net amount of each adjustment type. The full schedule includes net tax expense, excluded dividends and equity gains, revaluations, reorganisations, asymmetric foreign exchange, disallowed expenses, prior-period errors, accounting-policy changes, pensions, debt releases, stock compensation, arm’s-length adjustments, tax credits, realisation elections, asset gains, financing, intra-group consolidation, insurance reserves, additional tier-one capital, entries and exits, UPE transparency or deductible dividends, investment distributions, shipping and transition transfers. The resulting jurisdictional GloBE income or loss must reconcile to entity calculations.
Income adjustments must follow their economic treatment
Insurance-reserve movements matching excluded dividends or excluded equity gains are added back, while hedging foreign-exchange gains can follow an elected excluded-equity treatment. Qualifying debt-release income is removed through the relevant adjustment. A refundable or marketable credit booked as a reduction of tax but treated as GloBE income requires an income addition; a credit booked as income but treated as a tax reduction requires an income deduction. Article 9.1.3 transfer adjustments are separately identified. These classifications matter because simply using the financial-account net figure can put the same tax benefit in the wrong part of the ETR fraction.
Reconcile current taxes and negative-tax carry-forwards
Current covered-tax expense starts after Article 4.3 cross-allocation. Adjustments cover taxes in profit before tax, GloBE loss assets used, paid uncertain taxes, refundable and marketable credits, flow-through benefits, excluded-income taxes, other credits, refunds, three-year nonpayment, post-filing changes, elections, UPE reductions, distribution systems, deferred taxes and equity or OCI. Qualified refundable and marketable credits are distinguished from other credits and ordinary refunds. Negative-tax carry-forwards record opening balance, creation, use and closing balance. Use is limited to the smaller of the available balance and otherwise positive adjusted covered taxes; creation under Article 4.1.5 excludes the excess attributable to losses carried back.
Blended CFC and deferred-tax reporting
The blended-CFC table identifies recipient jurisdiction, subgroup and allocated tax, whether the jurisdiction supplies or receives that tax. Deferred-tax reporting starts with book expense, separates eligible loss-asset uplift from other minimum-rate recasts, and then applies adjustments to the recast amount. The detailed list covers excluded-income taxes, disallowed and unclaimed accruals, valuation or recognition changes, rate changes, credits, substitute loss carry-forwards, payments of earlier recaptured or unclaimed accruals, unrecorded loss assets, acquisitions and exits, UPE reductions and Article 9.1.3 transfers. The summary and detailed totals must agree.
Loss carry-backs and the five-year DTL recapture schedule
For domestic losses carried back, report each prior year’s deemed deferred-tax asset reversal and related tax refund, unless the immaterial-decrease election places the amount in the current year. Total deemed reversal is capped at the domestic loss multiplied by the minimum rate; its difference from the refund enters the covered-tax adjustment. The DTL table tracks original accrual cohorts for the current and five prior years and their subsequent reversals. Recapture-exception accruals are excluded. An unreversed fifth-prior-year liability reduces that original year’s covered taxes and triggers an ETR and top-up-tax recalculation; aggregation in the presentation does not replace the required underlying tests.
Opening deferred taxes and pre-transition asset transfers
The transition year itself is reported annually, but the opening transition tables are completed when the reporting year is that transition year. Opening DTA and DTL amounts are recast to the minimum rate where appropriate; a lower-rate loss DTA can be uplifted only where its GloBE-loss origin is demonstrated. DTAs from excluded items in transactions after 30 November 2021 are removed. Transfers between group or JV entities after that date and before transition have separate fields for seller jurisdiction, tax paid, seller net deferred tax, adjusted GloBE carrying value and buyer net deferred tax. Post-transfer capital expenditure, depreciation and amortisation must be reflected; DTA is positive and DTL negative in the net fields.
Record annual, five-year and GloBE-loss elections
Jurisdictional elections include asset-gain treatment, immaterial tax decreases, not applying SBIE and excess-negative-tax procedures, together with five-year equity-inclusion, stock-compensation, realisation and intra-group consolidation choices. Record election and revocation years for five-year choices. The GloBE-loss election must be made in the first return including that jurisdiction and cannot be made again after revocation. Qualified-ownership-interest records reconcile investment opening balance, additions, receipts and closing balance; reductions cannot drive investment below zero. Omitting the SBIE computation table is treated as an election not to use SBIE.
Eligible distribution-tax systems have four-year accounts
An Article 7.3 election creates deemed-distribution-tax recapture accounts by fiscal-year cohort. Payments, jurisdictional GloBE losses multiplied by the minimum rate and recapture-account loss carry-forwards reduce outstanding balances chronologically, never below zero. A balance remaining at the end of the fourth subsequent year requires recalculation. A constituent entity’s departure or transfer of substantially all assets can also require earlier-year recalculation. The return records the incremental top-up tax and the disposition recapture ratio based on the departing entity’s GloBE income relative to jurisdictional net income.
When tax-consolidated entities can be reported together
Part 3.2.4 can treat a tax-consolidated group as one entity only if taxable profits and losses are combined into one liability, all consolidated entities are wholly owned by the consolidator, all are in the same GloBE jurisdiction and the Article 3.2.8 intra-group consolidation election has been made. Identify the group TIN and every aggregated entity TIN. An entity joining or leaving the MNE during the year must still be reported individually. Outside the permitted simplifications, each entity’s income, current-tax and deferred-tax adjustments are reported separately as additions and reductions.
Cross-border income and tax allocations remain visible
Income-allocation rows identify the entity and counterparty, country, legal basis and amounts before and after each adjustment. Apply permanent-establishment allocation first, then remove non-group flow-through ownership, allocate flow-through income to PEs and allocate transparent income to constituent owners in the prescribed order. Tax-allocation rows identify the Article 4.3 basis, with blended CFC separately labelled, and include both current and deferred tax. Cross-border arm’s-length adjustments under Article 3.2.3 are not itemised where the relevant intra-group transactions do not exceed EUR 35 million in aggregate, but this is a reporting threshold rather than a calculation exemption. Article 3.2.7 financing-expense exclusions increase GloBE income.
Transparent UPEs and deductible-dividend regimes need owner evidence
Article 7.1 and 7.2 reductions identify the applicable provision, holder or dividend recipient, residence, tax-rate evidence and relevant ownership or deductible dividend. Natural persons are aggregated as specified; certain cases report their count by jurisdiction, while government, international, nonprofit and pension holders are classified. Where several nominal rates apply, the lowest can be reported only if it exceeds 15%. A wholly qualifying transparent UPE reports the designated wholly-owned exception instead of a reduction amount, and specified income, current-tax and deferred-tax tables are omitted. Its qualifying local transparent subsidiaries can have the same exception.
Entity elections and investment-distribution disclosures
Entity-level elections are reported even under simplified jurisdictional reporting. These include annual debt-release and unclaimed-accrual choices, five-year portfolio-dividend, hedging, investment-transparency and taxable-distribution choices, and fair-value adjustment treatment under Article 6.3.4. For the latter, identify the triggering year and whether the net adjustment is immediate or divided equally over five years. Article 7.6 information links owner and investment-entity TINs, distributions and deemed distributions, local creditable-tax gross-up and the owner’s share of undistributed net GloBE income for the tested year.
Shipping exclusion includes costs, taxes and the ancillary cap
For each entity, identify the qualifying international-shipping and ancillary activities, their revenue, attributable costs and resulting income, together with related payroll, tangible assets and covered taxes. The jurisdictional ancillary cap is 50% of international-shipping income. Ancillary income exceeding it remains GloBE income, with its direct and indirect costs included; corresponding payroll and tangible assets can enter SBIE. Costs, assets and taxes supporting excluded income must not also inflate ordinary tax or SBIE calculations. Shipping disclosures remain mandatory when simplified jurisdictional reporting is elected.
Disclose other accounting standards and calculate top-up tax
Identify every entity or JV using an acceptable or authorised standard different from the relevant UPE or JV consolidated standard, and name that standard. The top-up schedule records the percentage, SBIE, excess profit, additional current top-up tax and QDMTT, leading to jurisdictional top-up tax. The percentage is the minimum rate less ETR; it is applied to excess profit, then additional-current amounts and QDMTT are reflected under the applicable rules. QDMTT fields identify its accounting basis, payable amount, rate if above 15%, different blending basis, different currency and availability of SBIE and de minimis. When reporting under the QDMTT safe harbour, Part 3 uses its currency.
SBIE uses eligible local substance and correct time proportions
Payroll excludes capitalised costs already included in tangible assets and costs of excluded shipping or deductible-dividend income. If an employee works in the employer jurisdiction for 50% or less of the year’s group activities, only the local-time proportion enters. Tangible assets exclude property held for sale, finance lease or investment and assets supporting excluded shipping; an asset present locally for 50% or less of the year is proportioned by time. Apply the relevant fiscal-year percentages. Acquisition or disposal payroll follows costs included in consolidated accounts, while target asset value is proportioned to group membership.
Allocate SBIE for PEs and flow-through entities without duplication
PE payroll and assets are assigned to the PE jurisdiction and removed from the main entity; income exclusions under Articles 3.5.3 and 7.1.4 require proportional substance exclusions. Flow-through substance is allocated after PE allocations, to qualifying constituent owners or the UPE where the relevant provisions apply. It is excluded to the extent associated with reverse-hybrid income, non-group owners, excluded transparent-UPE income or employees and assets outside the owner jurisdiction. The return separately identifies allocated and excluded amounts and destination jurisdictions.
Explain every additional-current-top-up-tax recalculation
The return records each applicable ETR-adjustment article, prior fiscal year and previously reported and recalculated income, covered taxes, ETR, excess profit, percentage and top-up tax. Relevant provisions include Articles 3.2.6, 4.4.4, 4.6.1, 4.6.4, 7.3.5 and 7.3.7. DTL recapture refers to the fifth prior year, and deemed-distribution recapture to the fourth. Figures must include earlier recalculations already made. A separate Article 4.1.5 table applies where there is no positive jurisdictional net GloBE income and negative covered taxes: it compares expected tax, calculated as GloBE loss times 15%, with actual adjusted covered taxes.
Allocate IIR tax and recognise reporting exceptions
Ordinary jurisdictional tax is allocated among low-taxed entities using their positive GloBE income. Earlier-year recalculations instead use the relevant earlier income; Article 5.4.3 uses the qualifying negative-tax difference, and investment-distribution rules have their own basis. For each qualified-IIR parent, report identity, other owners’ attributable income, inclusion ratio, allocable tax, lower-tier IIR offset and payable tax. Entity-level allocation can be omitted where one parent takes 100% or all relevant parents have the same inclusion ratios across every relevant local entity. These exceptions also affect whether simplified jurisdictional reporting needs entity-level computation fields.
UTPR residual tax and cash-tax carry-forwards
The UTPR section covers low-taxed entities not eliminated by Article 2.5.2 and JV tax remaining after qualified IIRs. It deducts relevant IIR tax, using the UPE allocable JV share where appropriate; if no IIR applies, jurisdictional reporting can replace individual IDs. For each UTPR jurisdiction, report prior carry-forward, employees, tangible-asset net book value, UTPR percentage, allocated current tax, additional cash tax and remaining carry-forward. Investment-entity substance is excluded. PE substance follows the PE location; unallocated flow-through substance follows eligible entities in the creation jurisdiction or is excluded. A jurisdiction with outstanding carry-forward generally has a zero allocation percentage and is removed from the denominator, unless the all-zero exception applies.
Use the template and explanatory notes together
Amounts are generally entered as positive numbers even where a field describes an expense or reduction; specifically negative fields use the required negative presentation. The GIR’s detailed notes explain fields but do not replace or reinterpret the Model Rules, Commentary, administrative guidance or agreed safe harbours. A practical review links every reported amount to its source accounts, allocation schedule, election history and prior-year record, then checks that high-level summaries, entity totals, jurisdiction totals and IIR/UTPR results agree. Retain the original 2023 PDF alongside this explanation when reviewing historical filings.
Official source
This article independently explains the substantive contents of the official PDF, including the relevant conditions, procedures and annexes. The linked document remains the authoritative source for its original wording, and later changes should be checked separately.
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