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USAINTERNATIONAL TAX
Pillar Two: the September 2026 OECD package and the revised GloBE Information Return
On 11 September 2026 the OECD/G20 Inclusive Framework released a revised GloBE Information Return, new administrative guidance and a peer-review framework for domestic rules. Groups in scope should update their data and reporting processes now.
By the True CPA Tax TeamNovember 4, 20262 min read
The package builds on the January 2026 side-by-side agreement. It does not remove QDMTTs or every GIR obligation. It changes what groups report and how jurisdictions qualify their rules. For Latin American groups with US operations, and US groups with Latin American subsidiaries, the key point is data readiness.
The revised GIR
Adds reporting for the side-by-side safe harbour, the UPE safe harbour, the simplified effective tax rate and the substance-based tax incentive safe harbour.
Applies to GIRs for fiscal years beginning on or after 31 December 2025.
The revised XML schema has not been released yet.
Some new explanatory notes also apply to earlier fiscal years.
New administrative guidance
Explicitly conditional taxes: taxes that apply only if another jurisdiction’s IIR or UTPR applies are excluded from covered taxes. Conditional domestic minimum taxes generally cannot qualify as QDMTTs.
Mismatched fiscal periods: clarifies the QDMTT safe harbour when local fiscal periods differ from the UPE’s consolidation period.
More to come: further guidance on other potentially discriminatory tax features is expected before the end of 2026.
Legislative peer review
Peer review will replace self-assessment to decide whether IIR, UTPR and QDMTT laws are qualified.
Jurisdictions whose rules took effect on or before 1 April 2025 generally have three years to start the review.
What to do now
01Map which safe harbours each jurisdiction in the group will use for fiscal year 2026.
02Update data requests to subsidiaries for the new GIR fields.
03Document safe-harbour elections and their support.
04Check local filing deadlines and local QDMTT returns in each country.
05Monitor the OECD XML schema release and local implementation.
Watch out: the GIR changes depend on each jurisdiction’s domestic law. A safe harbour agreed at OECD level only helps where the local rules adopt it.
HOW TRUE CPA CAN HELPTrue CPA maps Pillar Two exposure by jurisdiction, builds the data model for the GIR and coordinates filings with local advisers across the Americas.Talk to a specialist
Legal basisOECD/G20 GloBE Model Rules; Side-by-Side Package (January 2026); Administrative Guidance and revised GloBE Information Return (11 September 2026); Terms of Reference and Assessment Methodology for the Full Legislative Review.SourcesOECD — Global Anti-Base Erosion Model Rules (Pillar Two)Grant Thornton — OECD updates Pillar 2 reporting and conditional tax guidance (22 Sep 2026)Loyens & Loeff — OECD releases new Pillar Two guidance, updated GIR and framework for legislative reviewsThis content is for information only and does not replace an analysis of each specific case.
