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ARTICLE · 18 MARCH 2025

Pillar Two: Jan. 2025 OECD Guidance (Part 2) – New York Office Snippet

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The GloBE Information Return (𝐆𝐈𝐑) is a standardized information return designed to facilitate compliance with and administration of the P2 rules.

NetherlandsTax
Michiel Schul
Michiel Schul
Steffie Klein
Steffie Klein
Daan Jongebloed
Daan Jongebloed

Loyens & Loeff New York regularly posts 'Snippets' on a range of EU tax and legal topics. This Snippet describes the updates in the Jan 2025 OECD guidance (𝐀𝐆) on Pillar Two (𝐏𝟐) compliance matters.

The GloBE Information Return (𝐆𝐈𝐑) is a standardized information return designed to facilitate compliance with and administration of the P2 rules. The AG contains three key updates related to the GIR and also clarifies whether a country's implementation of the P2 rules can be considered 'qualified' for P2 purposes.

1. GIR Multilateral Competent Authority Agreement (𝐌𝐂𝐀𝐀)

The GIR should in principle be filed in all jurisdictions with P2 rules where an in-scope multinational group (MNE) has a presence. However, if an MCAA is in place, the GIR only has to be filed in one country (𝐆𝐈𝐑 𝐅𝐢𝐥𝐢𝐧𝐠 𝐂𝐨𝐮𝐧𝐭𝐫𝐲) provided the GIR will be exchanged with others under the MCAA. The GIR Filing Country does not need to implement P2 but must have a qualified

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