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Pillar Two Compliance in 2026: What the September GloBE Information Return Update Means for EU Groups

The OECD’s September 2026 update to the GloBE Information Return gives multinational groups a more standardised framework for reporting global minimum-tax information. EU groups should align their data, entity mapping and filing controls before the relevant fiscal-year reporting cycle begins.

By NomadicTax Research Team · 5-8 min read ·

Why the updated GloBE Information Return matters

The OECD’s September 2026 GloBE Information Return (GIR) is designed to standardise the information multinational enterprise groups use to comply with and administer the Global Minimum Tax. The updated return incorporates the Side-by-Side Package released in January 2026 and is intended for fiscal years beginning on or after 31 December 2025. Although the GIR is an OECD framework rather than a standalone EU filing law, it is highly relevant to groups operating in EU Member States implementing the Pillar Two Directive.

What businesses should review

A group should not treat the GIR as merely a tax-form exercise. The filing depends on reliable information across legal entities, permanent establishments, ownership chains and jurisdictions. Review the following areas:

  • Entity inventory: Confirm that every subsidiary, branch and investment entity is correctly classified.
  • Jurisdictional data: Reconcile revenue, covered taxes, payroll, tangible assets and other data used in the effective-tax-rate calculation.
  • Safe-harbour support: Preserve the source data and calculations supporting any transitional or simplified treatment.
  • Filing responsibility: Determine which group entity will submit the central return and which jurisdictions may require local notifications or additional information.
  • Audit trail: Retain calculation files, source ledgers, intercompany data and management approvals in a controlled repository.

Practical example

Suppose a German-headquartered group has subsidiaries in France, Poland and the Netherlands, with a fiscal year beginning 1 January 2026. Its tax team should map each entity to the group’s consolidation structure, reconcile local tax returns with the data used for Pillar Two calculations, and document the basis for any safe-harbour treatment. A local accounting figure should not be copied into the GIR without checking whether it meets the relevant GloBE definition.

Action plan

Create a single Pillar Two data dictionary, assign owners for each data field and perform a dry-run return before the filing deadline is reached. Groups should also monitor the domestic implementation rules of each relevant EU jurisdiction, because the OECD return does not itself replace national filing or notification requirements. Early reconciliation is particularly important where financial reporting systems and tax systems use different entity codes or accounting periods.

Sources

1www.oecd.org
Official source for Pillar Two Compliance in 2026: What the September GloBE Information Return Update Means for EU Groups
2www.oecd.org
Official source for Pillar Two Compliance in 2026: What the September GloBE Information Return Update Means for EU Groups
3taxation-customs.ec.europa.eu
Official source for Pillar Two Compliance in 2026: What the September GloBE Information Return Update Means for EU Groups