Guidance

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

Updated 23 June 2026

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 applies where the filing deadline for the GIR is no later than 31 December 2026.

If the GIR is centrally filed in a jurisdiction listed at the bottom of this guidance (which largely replicates the Annex of the OECD’s paper) and HMRC receives 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 submit their overseas return notification (ORN) to HMRC on time to benefit from these arrangements. An ORN is treated as submitted on time if it is submitted to HMRC before any late filing penalties would arise (taking into account HMRC’s transitional approach to late filing penalties).

See How to report Pillar 2 Top-up Taxes for more details about when late filing penalties are due and HMRC’s transitional approach.

The ORN must specify the date the GIR was filed overseas. However, if software issues mean the GIR cannot be filed in the overseas jurisdiction before the ORN is due, the group should nevertheless file the ORN on time, but use a notional GIR filing date of 1 January 2026 in the ORN.

Local filing switch off

If a GIR has been centrally filed 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 within 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.

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 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