The OECD releases June 2026 Guidance on the use of the GIR XML Schema for first GloBE filings

On June 8, 2026, the OECD released the Guidance on the use of the GIR XML Schema for the first GloBE filing and exchange cycle.

The guidance was approved by the OECD/G20 Inclusive Framework on BEPS on  June 3, 2026 and is expressly directed at the first GIR filings and exchanges. It identifies 14 issues in the current GIR XML Schema or related validation rules and prescribes practical workarounds, including the use of substitute elements, additional data points, dummy values, bounded percentage values and the non-application of certain validation rules.

It accepts that some gaps exist between the GIR template, the XML Schema and the validation rules, and it gives taxpayers and authorities a common way to proceed without delaying the 2026 filing and exchange timetable.

In several places, the OECD instructs filers to use an XML element that does not literally match the relevant legal or GIR template item. In other places, the filer is told to report zero, cap a percentage, leave a redundant element blank, or use a dummy code.

The 14 issues and their practical implications

Issue 1: Missing ‘Adjusted Covered Taxes’ element in the jurisdiction-with-taxing-rights section

The first issue concerns point 3.1.6 of the GIR template, ‘Adjusted Covered Taxes.’ The OECD explains that the relevant XML path in the JurWithTaxingRights section does not contain a single element corresponding to that GIR item, although it does contain the four sub-elements below it. The prescribed workaround is to use the four sub-elements – AggCurrentTaxExpense, QRTCExpense, OtherTaxCredits and DeferTaxExpense – as the substitute for reporting the sum.

For MNEs, this is a ‘derived total’ problem. The filed XML will not contain a single value labelled ‘Adjusted Covered Taxes’ at this location. Instead, the amount must be reconstructed from the sub-elements. 

Issue 2: Missing Article 7.1.2 option for GloBE losses of a flow-through UPE

The XML enumeration under the UPE Adjustments section includes bases such as Article 7.1.1, Article 7.2.1 and Article 7.2.2, but does not include Article 7.1.2, which concerns GloBE losses incurred by a UPE that is a flow-through entity. Because the field is mandatory, it cannot simply be left blank.

The OECD instructs filers to use GIR1910 – Article 7.2.2 under the Basis element as a substitute when Article 7.1.2 is being elected, and to complete the related Reductions elements in the same way as for other adjustments. The filer must then complete an Additional Data Point: the Description should include ‘ADT1 Basis’; the Amount should match the amount reported in Reductions/Amount; and the Text should state ‘Article 7.1.2’ or, where relevant, ‘Article 7.1.2, Exception,’ together with the path to which the Additional Data Point relates. If GIR1910 is also genuinely needed for an Article 7.2.2 adjustment, the element should be repeated and used twice.

A literal XML read will show an Article 7.2.2 code even where the legal position is Article 7.1.2. The Additional Data Point is therefore the key interpretive mechanism that prevents the return from being misunderstood. 

Issue 3: No jurisdiction element in UTPRAttribution

The OECD notes that the UTPRAttribution element allows filers to indicate the jurisdictions to which UTPR taxing rights are allocated, but not the low-tax jurisdictions in respect of which UTPR top-up tax was generated. The guidance states that this element should not be used for 2026 filings because no jurisdiction has a UTPR applying in 2024; the OECD also states that the issue will be fixed in the schema when an opportunity arises.

For 2026 filings, the instruction is straightforward: do not use the element. For later periods, this issue should remain on implementation roadmaps because the UTPR becomes more relevant after the first cycle. 

Issue 4: Missing element for GIR 3.2.3.1.b.1 on equity gain or loss

The fourth issue concerns the absence of an XML element corresponding to GIR 3.2.3.1.b.1, which relates to the inclusion of equity gain or loss where an Equity Investment Inclusion Election is made. The OECD instructs filers to report the information as an Additional Data Point under GLOBEBody/JurisdictionSection/AdditionalDataPoint. The Description should include ‘ADT2 EquityGain,’ the relevant equity gain or loss should be reported in the Amount element, and the text should include the path to which the Additional Data Point relates; other elements under the Additional Data Point should not be completed.

This is another area where the Additional Data Point functions as a legal disclosure substitute. 

Issue 5: Covered taxes of the Constituent Entity after adjustment