Skip to main content
Guidance

Global Information Return (GIR) Filing and Exchange: Transitional approach

Published 19 May 2026

© Crown copyright 2026

This publication is licensed under the terms of the Open Government Licence v3.0 except where otherwise stated. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence/version/3 or write to the Information Policy Team, The National Archives, Kew, London TW9 4DU, or email: psi@nationalarchives.gov.uk.

Where we have identified any third party copyright information you will need to obtain permission from the copyright holders concerned.

This publication is available at https://www.gov.uk/government/publications/global-information-return-filing-and-exchange-transitional-approach/global-information-return-gir-filing-and-exchange-transitional-approach

On 18 May 2026 the OECD published a paper setting out the approach that some of the jurisdictions that have implemented Pillar 2 for 2024 will take in respect of the central filing and exchange of Global Information Returns (GIRs). The UK supports this approach and HMRC will act in accordance with it.

Applicability

This transitional approach will apply where the filing deadline for the GIR is no later than 31 December 2026.

If the GIR is centrally filed in one of the jurisdictions included in the Annex of the OECD’s paper (which is replicated below) and HMRC receive the relevant GIR information from the other authority within six months of the filing deadline the UK has decided that it will:

  • not enforce the local filing of the GIR
  • reduce certain penalties to nil

The group must also submit their overseas return notification (ORN) to HMRC on time to benefit from these arrangements.

More detail on this approach is provided below.

Local filing switch off

If a GIR has been centrally filed by the filing deadline in any of the jurisdictions listed below, and the ORN has been submitted on time, HMRC will not generally require an information return to be submitted to the UK.

Penalties

An ORN is only valid if, at the time it is submitted the GIR has been submitted to an overseas jurisdiction, and that overseas jurisdiction has an agreement with HMRC under which the jurisdiction will share the information contained with the GIR.

The filing of an invalid ORN would usually lead to penalties. If an invalid ORN has been submitted, the obligation on the group to submit a GIR locally in the UK would not have been removed. Failure to submit a GIR on time could attract late filing penalties.

However, in view of the fact that all the jurisdictions listed below have indicated their intention to enter into an agreement to exchange files with HMRC, HMRC will initially reduce the late filing penalty for the GIR to zero if an ORN naming one of these jurisdictions is filed on time, and a GIR is filed in that jurisdiction by the UK’s filing deadline (aligned with the OECD’s Model Rules).

Failure to receive the GIR on exchange

Should HMRC not receive the centrally filed GIR within six months of the filing deadline, HMRC may then contact the group to enforce the local filing requirement and notify it that it will begin to charge late filing penalties until the group’s obligations are met in the UK.

Central filing in the UK

The UK’s GIR filing portal opened on 19 May. For more information on how to submit an ORN and GIR in the UK please check the How to report Pillar 2 Top-up Taxes and Choose the right software for Pillar 2 Top-up Taxes pages.

Jurisdictions

The below jurisdictions expected to be ready for central filing before 31 May 2026:

  • Australia
  • Austria
  • Barbados
  • Belgium
  • Bulgaria
  • Canada
  • Croatia
  • Czech Republic
  • Denmark
  • Finland
  • France
  • Germany
  • Gibraltar
  • Hungary
  • Ireland
  • Italy
  • Japan
  • Liechtenstein
  • Luxembourg
  • Netherlands
  • Norway
  • Portugal
  • Republic of Korea
  • Romania
  • Spain
  • Sweden
  • Switzerland
  • Slovenia
  • South Africa
  • Turkey
  • United Kingdom
Back to top