Finland Issues Detailed Guidance on the GIR XML

In April 2026, Finland issued detailed guidance on the Finnish implementation of the GloBE Information Return (GIR), which follows the OECD’s 2025 GIR standard, and is filed in XML through OmaVero.

Domestic legal basis

Chapter 8 of the Finnish Minimum Tax Act requires a Finnish-located constituent entity is to file the GIR with the Finnish Tax Administration. The filing may be made by the constituent entity itself or by a designated local entity on its behalf under  chapter 8, section 3. 

The Act also recognises centralised filing. A Finnish entity is relieved from filing a Finnish GIR where a compliant GIR is filed by the ultimate parent entity or a designated filing entity located in a jurisdiction that has an effective competent authority agreement with Finland for the reporting fiscal year. In that case, the Finnish constituent entity or designated local entity must notify the Finnish Tax Administration of the identity and jurisdiction of the GIR filer (chapter 8, section 5). In practice, intra-EU exchange is based on DAC9, while non-EU central filing requires a signed and activated GIR MCAA relationship by the filing deadline; otherwise, the Finnish GIR must be filed locally.

The required GIR contents are set out in chapter 8, section 7: identification details and tax identification numbers of constituent entities, their jurisdictions and GloBE status, corporate structure and ownership information, data needed to compute ETR and top-up tax, IIR and UTPR allocations, and the group’s annual and five-year elections. The Finnish Tax Administration has express power to issue more detailed rules on the data, filing method and timing under chapter 8, section 6. It has exercised that power through its 17 December 2025 decision, which requires GIR data in the DAC9 Annex VII standard model and filing electronically in OmaVero as an XML file; the decision first applies to filings made in 2026.

The statutory deadline is 15 months after the fiscal year end. For the first filing, Finland applies an 18-month deadline, and the first GIR deadline is 30 June 2026. 

OECD framework

The Finnish GIR is closely tied to the OECD standard GIR. The OECD Model Rules’ Article 8.1 requires each constituent entity in an implementing jurisdiction to file a standardised GloBE information return, unless the return is filed centrally by the UPE or a designated filing entity in a jurisdiction with a qualifying competent authority agreement. Article 8.1 also sets out the core information categories: entity identification, corporate structure, ETR and top-up tax computation data, IIR and UTPR allocation data, and elections. Article 8.3 further provides that tax administrations should, subject to domestic law, apply the GloBE rules in accordance with Agreed Administrative Guidance.

The OECD’s GloBE Information Return (January 2025) is the key reporting standard. It is designed to support both local and central filing, and the OECD states that a group should provide the same information whether a GIR is filed locally or centrally and exchanged. The 2025 GIR also adopts a dissemination approach: the UPE jurisdiction receives the whole GIR, jurisdictions with taxing rights receive the relevant ETR, top-up tax, allocation and attribution sections, and implementing jurisdictions where constituent entities are located receive general information and corporate structure data.

The XML layer is addressed by the OECD’s GloBE Information Return (Pillar Two) XML Schema: User Guide for Tax Administrations, published on 15 January 2025. The XML schema is primarily designed for automatic exchange between tax administrations, but also suitable for domestic GIR filings where domestic law permits. 

Finland’s technical guide

The Finnish Tax Administration’s technical guide states that the Finnish GIR gives the information required under chapter 8 of the Minimum Tax Act, that the GIR data content follows the OECD’s January 2025 GIR standard, and that the XML filing is based on the OECD GIR XML Schema User Guide. The guide also notes that the schema meets DAC9 needs and that the Finnish instructions apply for fiscal years beginning on or after 31 December 2023.

Finland-specific GIR XML points

Filing channel, authentication and file format

The GIR is filed as an XML file through OmaVero. The Finnish Tax Administration’s guide states that there is no OmaVero test environment for GIR filings and that authentication uses Suomi.fi identification and authorisations. The Finnish Tax Administration also states that Pillar Two filings can be submitted in OmaVero from 30 January 2026.

The XML must use UTF-8 encoding, but the Finnish guide recommends using ISO-8859-1 characters encoded in UTF-8 for compatibility. Certain XML-sensitive characters must be escaped – including ampersands, angle brackets, apostrophes and quotation marks – and the strings --, /* and &# must not appear in the XML data. Amounts are rounded to the nearest whole integer for reporting, although the underlying top-up tax calculations should use exact figures. Boolean values are reported as 1 for true and 0 for false. GloBE percentages are reported as decimals between 0 and 1, with 25% reported as 0.25.

Message header

The message header is a common source of errors because it differs from what some groups expect from exchange-of-information XML. In Finland:

Finnish identifiers and TIN rules