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Pillar 2 - Common understanding of implementing jurisdictions on the central filing and the exchange of GloBE Information Return (GIR)

Date:

On 18 May 2026, the OECD published a Common understanding of implementing jurisdictions on the central filing and the exchange of GloBE Information Return (GIR).

33 of the 37 implementing jurisdictions with a reporting obligation starting from the 2024 Fiscal Year, where multinational enterprise groups (MNE groups) are required to submit their GloBE Information Return (GIR) by 30 June 2026, have stated that they will accept central filing of the GIR, provided that it is exchanged by 31 December 2026 at the latest.

To enable this exchange, jurisdictions must sign and activate the Multilateral Competent Authority Agreement on the exchange of GloBE information (GIR MCAA). It is expected that some jurisdictions will not be able to activate the GIR MCAA before 30 June 2026, but will do so before the exchange deadline of 31 December 2026.

The jurisdictions concerned, among them Belgium, have agreed to apply a flexible approach to these obligations: they will not impose fines, nor will they enforce the local filing obligation, provided that the GIR is centrally filed in another implementing jurisdiction and that this is notified in time via the GIR notification.

However, if eventually the central filing has not been sent to that jurisdiction by the relevant exchange deadline, that jurisdiction reserves the right to take measures and enforce local filing. Should Belgium require local filing in this way, it will communicate this in due time and set a deadline for submission. Belgium will not impose fines if the filing is made before that deadline.

The annex to the Common Understanding contains the list of jurisdictions* that are expected to be ready for centralised filing for the 2024 Fiscal Year.

This principle also applies to EU Member States that have not transposed DAC9 in time.

*As Cyprus is not a member of the Inclusive Framework on BEPS, it is not included in this list. However, based on the EU Directive, Cyprus is considered a qualifying country for central filing.

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