Tax Planning

Strategic Tax Planning for Global Minimum Tax (Pillar Two): What MNEs Need to Know

With the OECD’s new package to enforce the Global Minimum Tax (GMT), multinational enterprises must adapt fast: this article explains the rules, reveals planning levers, and offers actionable strategies.

By NomadicTax Research Team • 5-8 min read • September 16, 2026

## Understanding the Global Minimum Tax Framework The **OECD/G20 Inclusive Framework** released on **11 September 2026** a package to support consistent implementation of the Global Minimum Tax (GMT), also called the GloBE Rules. It includes updates to the GloBE Information Return (GIR) and new guidance on the model rules. This will ensure the tax liability calculations and reporting are more standardized across jurisdictions. ([oecd.org](https://www.oecd.org/en/about/news/announcements/2026/09/global-minimum-tax-inclusive-framework-releases-a-package-to-strengthen-consistency-and-certainty-for-mnes-and-jurisdictions.html?utm_source=openai)) Key elements: - The *Terms of Reference* for a full legislative review process to assess jurisdictions’ compliance with GMT implementation. ([oecd.org](https://www.oecd.org/en/about/news/announcements/2026/09/global-minimum-tax-inclusive-framework-releases-a-package-to-strengthen-consistency-and-certainty-for-mnes-and-jurisdictions.html?utm_source=openai)) - Updates to the GIR, which applies to fiscal years commencing **on or after 31 December 2025**, to reflect simplifications from the Side-by-Side package. Jurisdictions will need to adopt the revised XML schema once published. ([oecd.org](https://www.oecd.org/en/about/news/announcements/2026/09/global-minimum-tax-inclusive-framework-releases-a-package-to-strengthen-consistency-and-certainty-for-mnes-and-jurisdictions.html?utm_source=openai)) - Clarifications regarding “explicitly conditional taxes” (taxes triggered only by IIR or UTPR exposure) as not creditable Covered Taxes. Also guidance on using local financial accounting standards under QDMTT when fiscal periods misalign with the ultimate parent entity. ([oecd.org](https://www.oecd.org/en/about/news/announcements/2026/09/global-minimum-tax-inclusive-framework-releases-a-package-to-strengthen-consistency-and-certainty-for-mnes-and-jurisdictions.html?utm_source=openai)) ## Planning Levers for Multinational Enterprises (MNEs) To adapt and benefit from the GMT regime, firms should consider the following: **Leverage the Safe-Harbour and Reviewed Rules** - The GIR simplifications and XML schema changes may reduce complexity for MNEs with straightforward structures. Firms should assess whether their current tax data and systems are aligned with the new GIR formats. - Stay alert for further guidance on what constitutes discriminatory or conditional taxes, and plan to avoid exposure to non-creditable taxes. **Align Jurisdictional Structure and Tax Residency** - With peer reviews of domestic laws slated under the review framework, jurisdictions may be recommended to amend rules. MNEs should check where their subsidiaries are, which laws are in effect, and ensure that their tax structure doesn’t expose them to unpredictable GMT liabilities. - Consider where financial accounting standards differ from local tax accounting or from those assumed under GMT—timing mismatches may create QDMTT issues. **Contract with Governments and Policymakers Where Possible** - Participate in public consultations, especially those relating to GIR or model rule interpretations, to influence how rules are applied. - Map potential upcoming changes and engage early with local tax authorities to understand pending amendments or peer review results. ## Practical Examples - A tech-MNE headquartered in Jurisdiction A with subsidiaries in Jurisdictions B and C may find that taxes in B conditioned upon exposure to IIR or UTPR are now no longer creditable. That can increase net GMT liability; the group should review all local tax policies to identify conditional tax triggers. - A manufacturing group with fiscal periods misaligned across entities should assess whether to align city, regional, or national accounts to avoid complications under QDMTT safe-harbour. - MNEs with operations in countries in early adoption phases (or not yet adopted domestic GMT) should build forecasts of effective tax rates (ETRs) under the full rules vs transitional regimes. ## Actionable Next Steps 1. **Audit your current global tax structure**: list jurisdictions, current tax obligations, deferred liabilities, and conditional taxes. 2. **Update internal reporting systems** to accommodate the new GIR formats and the revised XML schema. 3. **Simulate GMT impacts**: effective tax rate changes, how liabilities shift across jurisdictions, cash-flow implications. 4. **Stay engaged** with OECD consultation and compliant jurisdictions’ legislative changes. 5. **Train your finance and tax teams** on the GMT rules, especially the definitions of Covered Taxes, conditional taxes, and relevant exemptions. ## Why This Matters These changes aren’t theoretical—jurisdictions are already moving to implement GMT via legislation. The OECD report shows many countries have adopted or begun implementing Pillar Two in domestic law as of fiscal years starting in 2024 and 2025. ([oecd.org](https://www.oecd.org/en/publications/tax-policy-reforms-2026_43d18a55-en/full-report/tax-policy-reforms_82075677.html?utm_source=openai)) Failing to plan now could lead to: - Unexpected tax liabilities - Reputational risk in jurisdictions seen as non-conforming - Loss of tax credits or exposure to additional top-up taxes **Bottom line**: Global Minimum Tax rules are entering their enforcement phase. For MNEs, this is the moment to align operations, structures, reporting, and strategy to reduce risk and seize certainty.