Japan’s Pillar 2 Filing Portal is Open

Japan has launched its Multinational Enterprise Information Reporting Portal for filing Pillar 2 returns.

Forms are filed via the Japanese E-Tax System in the Multinational Enterprise Information Reporting Portal. Returns related to global minimum tax for the fiscal year starting after April 1, 2024, are accepted from September 16, 2025.  Information is submitted via a CSV file or XML file. The forms include:

GIR

GloBE Information Returns (GIRs) must be filed within one year and three months from the day following the end of each fiscal year under Article 150-3 of the GloBE Act. This is increased to one year and six months for the first fiscal year an MNE is subject to the GloBE Rules in Japan under Article 150-3(6)) of the GloBE Act. In June 2025 the updated GIR was provided (for the January 2025 OECD GIR update).

This can be filed as a CSV file or XML file.  Guidance is provided on the information submitted in the GIR and the structure of the CSV file.

Notification of filing entity

Article 151-3 provides for the standard exemption for filing a GIR (ie if a GIR is filed by a designated entity or the UPE and there is an automatic exchange of information in place). If this applies a notification must be made by the standard GIR filing deadline.

The designated entity form should be created as a CSV file then converted to XML. The guidance provides an excel version of the form that can be used.

Tax Returns

Article 82-6 of the Law  requires submission of an additional self- assessment return (a ‘GloBE Top-Up Tax Return’) by the GIR filing deadline if there is an IIR top-up tax liability. Article 82-14 of the Corporation Tax Act requires the submission of a UTPR tax return within 15 months from the end of the fiscal year (increased to 18 months in the transitional year). The UTPR applies from April 1, 2026. The UTPR tax return must be accompanied by the consolidated financial statements of the ultimate parent entity of the MNE group for the relevant fiscal year and other documents prescribed by an Ordinance of the Ministry of Finance.

Article 82-22 requires the submission of a QDMTT tax return (for entities with an amount of QDMTT payable) within 15 months of the end of the fiscal year (18 months in the transitional year). The QDMTT applies from April 1, 2026.

This will include the following information:

(i) GloBE income for QDMTT purposes

(ii) The amount of QDMTT payable

(iii) The basis for calculating these amounts as provided by an Ordinance of the Ministry of Finance.

The QDMTT tax return must be accompanied by financial statements for the entity which are the basis for the preparation of consolidated financial statements of the ultimate parent entity of the MNE group.

Appendix 20 to the Law contains the GMT returns. The forms should be submitted as a CSV file. It is recommended to use the Tax Return Data (CSV) Creation Tool for GMT Returns. Guidance on the preparation of CSV files for global minimum tax returns is also provided.

Note that when logged in a test environment is available to check for errors.