Pillar 2: simplification for filing GloBE Information Returns
The OECD has published a common understanding among jurisdictions that have implemented qualified top-up taxes. It responds to the approaching deadline for filing GloBE Information Returns and includes a commitment, under certain circumstances, not to require the filing of simplified jurisdictional information returns or impose penalties for failing to file them.
According to the OECD’s updated list, a total of 37 jurisdictions have introduced a qualified top-up tax with effect for the 2024 fiscal year. Multinational corporate groups operating in these jurisdictions must file a GloBE Information Return (GIR) for 2024 by 30 June 2026, and the information from the central filing must be shared with the other relevant jurisdictions by 31 December 2026 under the applicable Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA). If no such agreement is in force between the jurisdiction where the GIR is filed centrally and another jurisdiction in which the group operates, the group must file a jurisdictional (simplified) information return in that other jurisdiction.
Given that the relevant GIR MCAAs are not yet effective in many countries and a number of them do not yet have conditions in place allowing for central filing, most countries that introduced qualified top-up taxes for 2024 have agreed to refrain from imposing penalties and will not require the filing of a jurisdictional information return. This applies on the condition that:
- the group files a full GIR containing information for the entire group centrally in one of the 33 jurisdictions that are expected to have an operational filing system by 31 May 2026 (these are, in essence, the jurisdictions that have signed up to the common understanding, including the Czech Republic), and
- the local constituent entity files a notification of the central filing of the GIR (by 30 June 2026).
If the information from the centrally filed GIR is not provided to the relevant jurisdiction by 31 December 2026, that jurisdiction may proceed to enforce the obligation to file a jurisdictional GIR.
Of the countries that had already introduced qualified top-up taxes for 2024, the Bahamas, North Macedonia, the Slovak Republic and Vietnam had not joined the common understanding as of 12 May 2026. Greece and Poland have joined only in relation to EU member states with an operational central filing system.
What could this common understanding mean for constituent entities operating in the Czech Republic? If the GIR is filed in countries on the list that are not in the EU (e.g. the United Kingdom, Canada, Japan, Switzerland or Korea), it should be sufficient in the Czech Republic to file a notification of GIR filing, without the need to file a simplified information return. In other words, the same approach should apply as if the GIR were filed within the EU. However, this will depend on the approach taken by the Ministry of Finance and the financial administration, which is not yet known.
More detailed information can be found in the KPMG summary.