14
Sep
What happened?
The OECD/G20 Inclusive Framework (IF) on 11 September 2026 released a package of Pillar Two materials, including a revised GloBE Information Return (GIR), a framework for the full legislative review of jurisdictions’ Pillar Two rules, and Administrative Guidance on certain conditional taxes and issues with respect to Qualified Domestic Minimum Top-up Taxes (QDMTT) fiscal-period mismatches.
The revised GIR implements reporting changes arising from the January 2026 Side-by-Side (SbS) Package. For qualifying US-parented groups applying the SbS safe harbour, certain...