GloBE Information Return
- Applies
- FY2025 onwards
- Reviewed
- Rule
- P2-GIR-2026.1
Which GloBE Information Return version should be filed?
The September 2026 return for fiscal years starting on or after 31 December 2025. A group electing the side-by-side safe harbour files only parts of it.
Per GloBE Information Return (September 2026)
The September 2026 GloBE Information Return, which incorporates the Side-by-Side Package, is used only for Fiscal Years commencing on or after 31 December 2025; earlier years use the earlier template. A group that elects the Side-by-Side Safe Harbour provides to a jurisdiction with an IIR or UTPR only Section 1 of the return, without Section 1.4; remains subject to the QDMTT, so provides to a QDMTT-only jurisdiction Section 1 without 1.4 and the jurisdictional section; and provides the same to a jurisdiction that has both. A group that has not elected it files the full return.
The return is separate from the tax return and payment, which each jurisdiction's own rules govern.
What the result turns on
The template follows the Fiscal Year
A Fiscal Year commencing on or after 31 December 2025 uses the September 2026 template. The Side-by-Side Safe Harbour starts a day later, on 1 January 2026, so a year commencing on 31 December 2025 files on the new template but cannot elect it.
Reduced reporting under the safe harbour
- IIR or UTPR jurisdiction: Section 1 only, without Section 1.4
- QDMTT-only jurisdiction: Section 1 without 1.4, plus the jurisdictional section, because the QDMTT still applies
- A jurisdiction with both: Section 1 without 1.4, plus the jurisdictional section
An election before 2026 is not available
The safe harbour does not affect Fiscal Years commencing before 1 January 2026, so no reduced return applies to them.
More than the return
A jurisdiction may require more data points for its own tax return and payment, and a tax administration may ask for supporting information.
Order of testing
- 1
The template for the Fiscal Year
Which version applies.
- 2
The Side-by-Side Safe Harbour election
How much of it is filed.
Examples
Illustrative scenarios — ours, not the authority’s — each computed live by this rule. Change any fact and the outcome is the rule’s, not a hand-written answer.
A 2026 year, no election
A Fiscal Year commencing 1 January 2026, to a jurisdiction with an IIR or UTPR, with no election.
Computed
The September 2026 GloBE Information Return applies as computed: the Fiscal Year starts on 2026-01-01, on or after 2025-12-31. With no Side-by-Side Safe Harbour election the full return is filed, including Section 1.4. The return is separate from the tax return and payment, which the jurisdiction's own rules govern, and a tax administration may still ask for supporting information. Based on what you supplied.
Decided by the template for the fiscal year
Elected, to a QDMTT-only jurisdiction
The same year with the Side-by-Side Safe Harbour elected, filing to a QDMTT-only jurisdiction.
Computed
The September 2026 GloBE Information Return applies, with reduced reporting, as computed: the Fiscal Year starts on 2026-01-01, and with the Side-by-Side Safe Harbour elected Section 1 (without Section 1.4) and the jurisdictional section for that jurisdiction go to a QDMTT-only jurisdiction, because the group remains subject to the QDMTT (Annex A Chapter 5 paragraphs 28 and 29). The return is separate from the tax return and payment, which the jurisdiction's own rules govern, and a tax administration may still ask for supporting information. Based on what you supplied.
Decided by the side-by-side safe harbour election
An earlier year
A Fiscal Year commencing 1 January 2025.
Computed
The earlier GloBE Information Return template applies as computed: the Fiscal Year starts on 2025-01-01, and the September 2026 template is used only for Fiscal Years commencing on or after 2025-12-31. The full return is filed. The return is separate from the tax return and payment, which the jurisdiction's own rules govern, and a tax administration may still ask for supporting information. Based on what you supplied.
Decided by the template for the fiscal year
Try it
Supply the facts and this rule computes the outcome in your browser, live. Leave a determination undecided and it blocks the result — it is never read as a no.
Not computed yet
3 inputs still need your determination:
- What is the first day of the Reporting Fiscal Year — the year the return is about — as a calendar date?
- What has the jurisdiction the return goes to implemented — an IIR or UTPR only, a QDMTT only, or both a QDMTT and an IIR or UTPR?
- Has the Filing Constituent Entity elected the Side-by-Side Safe Harbour for the Fiscal Year?
Computed in your browser from the figures you supply. Nothing is sent anywhere, and the result is a computation against a rule — reference, not tax advice.
Sources
GloBE Information Return (September 2026)
The template, its cover note and Annex C
https://www.oecd.org/content/dam/oecd/en/publications/reports/2026/09/tax-challenges-arising-from-the-digitalisation-of-the-economy-globe-information-return-september-2026_16d0f09e/0f9da895-en.pdfConsolidated Commentary to the GloBE Model Rules (May 2026) — Annex A, Chapter 5, paragraphs 28 and 29
Reporting where the Side-by-Side Safe Harbour is elected
https://www.oecd.org/content/dam/oecd/en/publications/reports/2026/05/tax-challenges-arising-from-the-digitalisation-of-the-economy-consolidated-commentary-to-the-global-anti-base-erosion-model-rules-2026_24289ddf/4377e89f-en.pdfAdministrative Guidance on Article 8.1.4 and Article 8.1.5 (January 2025)
The basis on which the return is completed
https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/global-minimum-tax/administrative-guidance-article-8-1-4-article-8-1-5-globe-rules-pillar-two-january-2025.pdf