Three linked implementation outputs

On 11 September the OECD/G20 Inclusive Framework released a full legislative-review methodology, an updated GloBE Information Return and administrative guidance. The package addresses consistency between implementing jurisdictions and the information multinational groups supply.

The updated GIR incorporates January's Side-by-Side simplifications. The OECD says these revisions apply only to returns for fiscal years commencing on or after 31 December 2025.

The technical distinctions

The guidance excludes explicitly conditional taxes from Covered Taxes where their application depends on the taxpayer being subject to another jurisdiction's IIR or UTPR. It also addresses mismatching accounting periods when local financial accounts are used for QDMTT safe-harbour purposes.

At the September release, the revised XML schema was still being developed. The current OECD resource page reviewed for this update lists the September GIR alongside the earlier schema and first-cycle guidance; this article does not claim a revised schema has been released.

What groups should change

T&M analysis: maintain a reporting-version register identifying which GIR applies to which fiscal year. A single template rolled across all reporting periods could use the wrong version, even when the underlying accounting data is correct.

Tax-characterisation and fiscal-period decisions should be recorded alongside the calculation. That makes it easier to explain why a tax was excluded or why local accounts were used, and to assess later guidance without rebuilding the analysis from memory.