Japan Issues Updated GloBE Information Return

On June 30, 2025, Japan issued its updated GloBE Information Return (GIR) to reflect the OECD GIR changes in January 2025.

Key changes in the updated GIR include aspects of the June 2024 OECD Administrative Guidance, including:

Jurisdictional computations relating to deferred tax accounting: Deferred Tax adjustments

The updated GIR adds in additional disclosures to reflect the June 2024 OECD Administrative Guidance in relation to differences between the GloBE and accounting carrying value of assets:

– Deferred tax expense in relation to assets or liabilities for which the GloBE carrying value is different to the accounting carrying value

– Deferred tax expense based on the GloBE carrying value of assets or liabilities

It also requires additional information for Aggregate DTL recapture accounts (to reflect the June 2024 OECD Administrative Guidance):

1. Reporting Fiscal Year 2. Prior Fiscal Year

a. Amount of pre-Transition Year DTLs

b. Amount of Outstanding Balance

c. Amount of Unjustified Balance

Jurisdictional safe harbours and exclusions: Characteristics of the jurisdiction

The updated guidance adds in a new (4) to require the disclosure of  ‘a Jurisdiction with taxing rights’.

This is required as a QDMTT Safe Harbour jurisdiction or a jurisdiction with an IIR that applies to domestic Entities will have taxing rights in respect of itself. In addition, multiple jurisdictions may have taxing rights in respect of the same other jurisdiction (eg a UPE and POPE). In this case, both the UPE jurisdiction and the POPE jurisdiction need to be reported.

The updated guidance adds in a new (5) to require the disclose of the ‘Existence of reportable differences (Yes/No)’.

The Filing Constituent Entity selects ‘Yes’ for a jurisdiction when either the MNE Group has reported that it is eligible for a safe harbour or exclusion in Section 2 when it is not eligible for the same safe harbour or exclusion under the domestic law of the relevant jurisdiction with taxing rights or, the MNE Group has reported that it is not eligible for a safe harbour or exclusion in Section 2 when it is eligible for the same safe harbour or exclusion under the domestic law of the relevant jurisdiction with taxing rights.

Constituent Entity Elections

It includes updates to require disclosure of the

– Election to apply the Simplified Calculations for NMCEs (Simplified Calculations Safe Harbour)

– Unclaimed Accrual Five-Year election (Article 4.4.7) (Under the June 2024 OECD Administrative Guidance the Filing Constituent Entity can make an Unclaimed Accrual Five-Year Election for a deferred tax liability for a general ledger account or an Aggregated DTL Category irrespective of the reversal time period).

For a detailed analysis of the changes in the updated January 2025 OECD GIR see A Review of Changes in the OECDs Updated January 2025 GloBE Information Return