The OECD’s May 2026 Pillar Two guidance: central GIR filing, 52–53-week fiscal years and the updated Central Record

On May 18 2026, the OECD provided three Pillar Two updates: a common understanding relating to late-filing penalties/enforcement for jurisdictions implementing the Global Minimum Tax from 2024, further Administrative Guidance on the Transitional UTPR Safe Harbour for 52–53-week fiscal years, and an update to the Central Record for jurisdictions with qualifying status. 

The Common Understanding

In principle, an MNE group should not have to file the full GIR separately in every implementing jurisdiction. Instead, the GIR can be centrally filed in the jurisdiction of the Ultimate Parent Entity or a Designated Filing Entity, provided the relevant notifications are filed and the central filing jurisdiction exchanges the relevant GIR information with other jurisdictions under the agreed exchange framework.

The OECD notes that 37 jurisdictions have implemented a QIIR and/or QDMTT applying to in-scope MNEs from their 2024 fiscal year. The GIR filing deadline is June 30, 2026, and the central filing jurisdiction is expected to exchange relevant GIR information with other implementing jurisdictions by 31 December 2026 under the GIR MCAA and dissemination approach.

The  risk is that some jurisdictions may not have a reliable GIR filing portal by the filing deadline, or may not have formally activated exchange relationships under the GIR MCAA before the filing deadline, even if exchanges are expected to be in place by year-end.

The common understanding is directed at this.  Those jurisdictions have agreed to use mechanisms available under their domestic laws to avoid adverse consequences where an MNE group centrally files the GIR in a jurisdiction that is operationally ready, even if some exchange relationships are not yet fully activated by the filing deadline.

The relief is, however, narrow. A jurisdiction may waive penalties that would otherwise apply to local GIR filing obligations, or may refrain from enforcing the local GIR filing obligation before the relevant GIR exchange deadline, where the GIR has been centrally filed in one of the listed jurisdictions by the relevant filing deadline and the local GIR notification has been filed by the relevant deadline.

The annex lists 33 jurisdictions expected to be ready for central filing before 31 May 2026: Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Czechia, Denmark, Finland, France, Germany, Gibraltar, Greece, Hungary, Ireland, Italy, Japan, Korea, Liechtenstein, Luxembourg, the Netherlands, Norway, Poland, Portugal, Romania, Spain, Sweden, Switzerland, Slovenia, South Africa, Turkey and the United Kingdom. Japan is subject to a specific limitation: its QIIR applies from 1 April 2024, and MNE groups will only be able to centrally file the GIR in Japan for fiscal years beginning on or after that date.

The common understanding also has important carve-outs. The Bahamas, North Macedonia, the Slovak Republic and Vietnam had not been able to join the common understanding as of 12 May 2026. Greece and Poland joined the common understanding with respect to EU Member States appearing in the annex.

The relief is also provisional. The common understanding expressly contemplates that a jurisdiction that has waived penalties or refrained from enforcing local filing may later take action, including enforcing local filing, if the centrally filed GIR has not been sent to that jurisdiction by the relevant exchange deadline.

It should be noted that this does not relieve MNEs from other domestic Pillar Two obligations, such as registrations, top-up tax returns, QDMTT returns, payment obligations or local information requirements outside the GIR itself.

Administrative Guidance on the Transitional UTPR Safe Harbour