OECD Updates on GIR Filings & UTPR Safe Harbour
OECD announced a series of updates and clarification on 18th May 2026. The updates focused on clarifying uncertainties regarding key aspects of Pillar Two compliance as the GIR filling for 2024 are due for some MNE Groups on 30th June 2026.
VSTN Newsletter covers the below aspects:
- Support Measures finalised for GIR fillings under the common understanding mechanism
- OECD update of the Central record for QDMTT
- OECD ‘s clarification UTPR Safe harbour for MN E Groups which follow the 52/53 weeks calendar
OECD Updates on GIR Filings and UTPR Safe Harbour
Guidance on additional support measures for GloBE Information Return (GIR) filings for fiscal years starting on or after 1 January 2024.
Key Aspects
Current GIR Compliance Requirement
The OECD has provided guidance on additional support measures for GloBE Information Return (GIR) filings for fiscal years starting on or after 1 January 2024. Currently, 37 jurisdictions have implemented either a QDMTT or an IIR for FY 2024 (the implementing jurisdictions), triggering GIR filing or exchange-of-information notification obligations for in-scope MNE Groups from 30 June 2026 for the 2024 reporting year.
Agreed On Relief
However, not all 37 jurisdictions have completed the process of signing the GIR MCAA, and some are not expected to fully operationalise their GIR filing portals in time for the applicable filing deadline. As a result, considerable uncertainty remains regarding local GIR filing obligations.
To address this concern, Implementing jurisdictions have agreed to waive penalties and will not require local GIR filing where it is centrally filed in one of the 33 listed jurisdictions and the GIR notification has been filed in the local jurisdiction by the relevant deadline; however, local filing may still be required if the GIR has not been exchanged with a jurisdiction by 31 December 2026, and the OECD is expected to publish by 31 May 2026 a list of jurisdictions with fully operational GIR filing portals.
Further Clarifications & Updates
Agreed On Relief (Continued)
The jurisdictions listed in the annex also include Barbados, Bulgaria, Czechia, Poland, Romania and Turkey, which are not yet signatories to the GIR MCAA. In addition, Greece and Poland have joined the common understanding only in respect of the EU member states referred to in the annex.
Update To Central Record
The latest update further confirms that Bahamas, Kenya, Kuwait and Oman have now completed the transitional qualification process for their Domestic Minimum Top-up Taxes (DMTTs), increasing the total number of jurisdictions qualified for IIR purposes to 44 and the number of jurisdictions qualified for DMTT and the QDMTT Safe Harbour to 50.
Qualification & Implementation Summary
| Indicator | Count / Status |
|---|---|
| Jurisdictions implementing QDMTT or IIR for FY 2024 | 37 |
| Jurisdictions listed for central filing relief (annex) | 33 listed jurisdictions |
| Non-signatories to GIR MCAA but included in annex | Barbados, Bulgaria, Czechia, Poland, Romania, Turkey |
| Jurisdictions qualified for IIR purposes (updated) | 44 |
| Jurisdictions qualified for DMTT & QDMTT Safe Harbour | 50 |
| Newly qualified DMTT jurisdictions | Bahamas, Kenya, Kuwait, Oman |
Important Deadlines & Operational Milestones
- GIR filing deadline for 2024 reporting year: from 30 June 2026
- OECD publication of jurisdictions with fully operational GIR filing portals: expected by 31 May 2026
- Backstop local filing requirement: If GIR not exchanged with a jurisdiction by 31 December 2026, local filing may be required
Source: OECD guidance on GloBE Information Return (GIR) filings and QDMTT/IIR safe harbour updates. Information as per current published measures.
About us
VSTN Consultancy is a Global Transfer Pricing firm with extensive expertise in the field of international taxation and transfer pricing. VSTN Consultancy has been awarded by International Tax Review (ITR) as Best Newcomer in Asia Pacific – 2024 and is ranked as one of the recommended transfer pricing firms. VSTN has also been nominated in 9 Categories under APAC, EMEA and Middle East Region ITR awards 2025. VSTN has its offices in India and Dubai.
Nithya Srinivasan, Founder of VSTN Consultancy, was named Middle East Transfer Pricing Practice Leader of the Year, recognizing her outstanding leadership and contribution to the profession. VSTN also received the Best Newcomer in the Middle East award from International Tax Review, showcasing its rapid growth and excellence in global transfer pricing advisory.
VSTN Consultancy has been honored with the Best Global Transfer Pricing Consultancy 2025 – India award at the prestigious Wealth & Finance Management Consulting Awards 2025.
Our offering spans the end-to-end Transfer Pricing value chain, including design of intercompany policy and drafting of Interco agreement, ensuring effective implementation of the Transfer Pricing policy, year-end documentation and certification, BEPS related compliances (including advisory, Masterfile, Country by Country report), safe harbour filing, audit defense before all forums and dispute prevention mechanisms such as Advance Pricing agreement. VSTNs senior partners have been ranked in ITR in the list of recognized Practitioners.
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Core Team
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Nithya Srinivasan
Srilakshmi Hariharan
S Ranjani
E Rajesh
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centest@vetmconsultancy.com
www.vstnconsultancy.com
Our Licensed Databases
| SNo | Database | Provider |
|---|---|---|
| 1 | TP Catalyst | Moody’s |
| 2 | ORBIS | Moody’s |
| 3 | Loan Module | Moody’s |
| 4 | IP & Royalty Data | Moody’s |
| 5 | Royalty Rates and Benchmark Module | ktMINE |
| 6 | Services CUT | ktMINE |
| 7 | EDF-X Bond Database | Moody’s |
| 8 | EDF-X Credit Risk Analytics | Moody’s |
| 9 | Loan Module | Royalty Range |
| 10 | Transfer Pricing Documenter (formerly Thomson Reuters Onesource) | Ryan |
| 11 | Prowess | CMIE |
As businesses expand across borders, navigating complex transfer pricing regulations becomes critical. At VSTN Consultancy, a global transfer pricing firm, we specialize in helping companies stay compliant and competitive across key markets including:
India | UAE | Singapore | USA | KSA | Dubai | Asia Pacific | Europe | Africa | North America
Whether you’re preparing for benchmarking intercompany transactions, or developing robust TP documentation, our team is here to support your international strategy and Compliance.
Contact us today to explore how we can partner with you to optimize your global transfer pricing approach.
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