The OECD/G20 Inclusive Framework on BEPS (Inclusive Framework) has today released a package to support the consistent implementation and application of the Global Minimum Tax, including a framework for the full legislative review process, updates to the GloBE Information Return (GIR), and new guidance on the application of the GloBE Model Rules.
The Terms of Reference and Methodology for the Full Legislative Review set out the framework that Inclusive Framework members will use to assess the consistency of domestic rules implementing the Global Minimum Tax (GMT).
This framework will allow Inclusive Framework members to undertake detailed peer reviews of implementing jurisdiction’s legislation to ensure alignment with the GloBE Model Rules and Commentary. Where inconsistencies are identified, the Inclusive Framework will issue recommendations to help jurisdictions address them.
The peer review process is designed to ensure the GMT is consistently applied across jurisdictions, helping to maintain a level playing field among implementing jurisdictions while providing greater tax certainty and reducing compliance costs for businesses through consistent and co-ordinated outcomes.
The Inclusive Framework has also released an update to the GloBE Information Return (GIR). The GIR is a standard information return used by implementing jurisdictions to collect the information needed to evaluate the accuracy of an MNE’s liability under the GMT.
The updated GIR incorporates the simplifications included in the Side-by-Side package agreed by the Inclusive Framework in January 2026. These revisions to the GIR will apply only to GIRs filed in respect of Fiscal Years commencing on or after 31 December 2025. A revised XML Schema is now being developed to incorporate these agreed changes. Inclusive Framework members are working to ensure this schema will be released shortly, allowing tax administrations and MNEs ample time to update their information collection, reporting, GIR filing and exchange systems.
In addition, further Administrative Guidance has been released to address the treatment of Explicitly Conditional Taxes and the use of Local Financial Accounting Standards under a QDMTT.
- Explicitly Conditional Taxes: The Side-by-Side package confirmed that conditional or discriminatory taxes will not be creditable as Covered Taxes and stated that further work would be undertaken to ensure this principle is consistently applied. This guidance confirms that taxes that explicitly apply to taxpayers only if they are subject to the IIR or UTPR in other jurisdictions, are not creditable as Covered Taxes. The Inclusive Framework will issue further guidance on other features of a tax that would result in such tax being considered discriminatory and therefore not being treated as a Covered Tax, with a view to releasing such guidance by the end of the year.
- Use of Local Financial Accounting Standards under a QDMTT in case of mismatching fiscal periods: Under certain conditions, a QDMTT may need to be calculated using financial accounts prepared based on the local financial accounting standard. This guidance clarifies that the QDMTT Safe Harbour continues to apply when the QDMTT is calculated based on the local financial accounting standard and the required QDMTT fiscal period does not align with the UPE’s Fiscal Year.
For more information on the OECD’s work on the Global Minimum Tax, visit: https://www.oecd.org/en/topics/sub-issues/global-minimum-tax.html.
For further information, please contact the Communications Office of the OECD Centre for Tax Policy and Administration.
