Finland Issues Detailed Guidance on the GIR XML
April 29, 2026
In April 2026, Finland issued detailed guidance on the Finnish implementation of the GloBE Information Return (GIR)
The December 2022 Safe Harbour and Penalty Relief Guidance provided for a Simplified Calculations Safe Harbour. The aim being to reduce or simplify the number of computations and adjustments an MNE is required to make under the GloBE Rules.
The only simplified calculations that have currently been developed by the OECD are the Non-Material Constituent Entity (NMCE) Simplified Calculations.
A number of jurisdictions already include the Simplified Calculations Safe Harbour in their GloBE legislation (see our Pillar Two GloBE Guides), including:
– Austria
– Bulgaria
– Germany
– Ireland
– Luxembourg
– Romania
– UK
The December 2023 OECD Administrative Guidance provides further information on the NMCE Simplified Calculations (for the Simplified Calculations Safe Harbour).
NMCEs are constituent entities of an MNE Group that are not consolidated on a line-by-line basis in the MNE Group’s audited consolidated financial statements solely for size or materiality grounds. It also includes any permanent establishments of these entities (providing the Main Entity is itself an NMCE.)
It should be noted that an entity will only be considered a NMCE if an external auditor has agreed that the entity does not meet the materiality standards and has been excluded from the consolidation process on those grounds.
Where an entity’s revenue exceeds EUR 50 million, the entity will only be an NMCE if its financial accounts are prepared in accordance with an Acceptable Financial Accounting Standard or an Authorised Financial Accounting Standard.
Given the significant practical difficulties MNEs may have in obtaining accurate reporting figures for NMCEs (as they aren’t included in the consolidated accounts), NMCEs can benefit from the following simplifications:
– The GloBE revenue and GloBE income of an NMCE is the total revenue of the NMCE as determined in accordance with the relevant CbC regulations.
– The adjusted covered tax of a NMCE is the income tax accrued as determined in accordance with the relevant CbC regulations (note that this excludes any deferred tax expenses, adjustments for non-current items and provisions for uncertain tax liabilities).
Relevant CbC Regulations are the Country-by-Country Reporting Regulations of the UPE Jurisdiction or of the surrogate parent entity jurisdiction if a Country-by-Country Report is not filed in the UPE Jurisdiction.
If the UPE jurisdiction does not have CbC requirements and an MNE Group is not required to file a CbC Report in any jurisdiction, Relevant CbC
Regulations are the OECD BEPS Action 13 Final Report and the OECD Guidance on the Implementation of Country-by-Country Reporting.
These simplified figures are then used for three tests under the Simplified Calculations Safe Harbour.
In April 2026, Finland issued detailed guidance on the Finnish implementation of the GloBE Information Return (GIR)
On April 10, 2026, Croatia issued a Draft Ordinance to provide for various administrative aspects of its Pillar Two regime.
The Netherlands has announced the opening of its Pillar Two filing from June 2026.
A guide to Norway’s three compliance workstreams for Pillar Two (suppleringsskatteloven): the GloBE Information Return (GIR), the foreign-filer notification, and the Norwegian top-up tax return.
A review of the remedial timing amendment that aligns New Zealand’s GloBE incorporation rules with the OECD’s January 2026 Side-by-Side Package.
On April 17, 2026, the Brazil opened up a consultation on proposed changes to its QDMTT regime to implement the Substance-based Tax Incentives (SBTI) Safe Harbour.
On 9 and 10 April 2026, the Dutch Tax Administration’s Pillar Two Knowledge Group published two administrative positions on the treatment of joint ventures under the Dutch Minimum Tax Act 2024.
A guide to Italy’s three-track Pillar Two process: the reporting-entity notification, the DAC9/GIR (Comunicazione Rilevante), and the domestic GloBE Return (Dichiarazione fiscale Globe) with related F24 payments.
A guide to Australia’s Pillar Two filing. It covers the separate local GIR XML filing, the foreign lodgement notification, and the Combined Global and Domestic Minimum Tax Return (CGDMTR), including the Australian IIR/UTPR tax return and Australian DMT tax return. It also flags the main ATO validation rules and the software / API points that matter if you are building or testing a filing process.
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