How to file the required information
GloBE information return, GIR
All constituent entities are under obligation to provide information for purposes of global minimum taxation on a new type of information return on top-up tax (the GloBE Information Return, GIR) according to the OECD standard. The return (GIR) must be filed within 15 months from the end date of the constituent entity’s accounting period. However, when filed for the first time, the due date is 18 months from the end of the accounting period.
Submittal of GIR returns can be centralised to a single consolidated entity of an MNE group. In this case, responsibility for submittal will fall on the ultimate parent entity of the MNE group or alternatively on a designated entity other than the ultimate parent. When the GIR returns are filed, the Tax Administration will send the information on, to be exchanged in an automated information exchange between the tax authorities of the countries where the entities are located.
The data content is based on the OECD standard. The filers of GIR returns will need to upload them as .xml files through MyTax. The content is defined in the OECD publication GloBE Information Return, and the return must conform to the schema released by the OECD.
When the safe harbour rule or the transitional rule for MNE groups and large Finnish groups at the earlier stages of their international activities is applicable, the top-up tax is reduced to zero but the entities will still have the obligation to file the returns. In these situations, the information return on top-up tax is filed with more limited content. The Tax Administration will release further instructions for submitting the returns.
Consolidated group enterprises concerned by the regulation must submit their first GloBE information returns in accordance with the international standard by 30 June 2026.
Notification of filing constituent entity
If your MNE group has centralised its submittal of the GloBE information return (GIR) to a country other than Finland, the constituent entity or the designated local entity in Finland will need to file a notification indicating the name of the filing constituent entity (subsidiary) being in charge of submitting the GIR return in the other country. The notification’s information content includes the identifier of the entiry submitting the return and the name of the relevant country or jurisdiction.
The due date for filing the notification in MyTax is within 15 months from the end date of your consolidated entity’s accounting period. However, when filed for the first time, the due date is 18 months from the end of the accounting period. The first due date for the notification will be 30 June 2026.
Top-up tax return
The consolidated entities that must pay a top-up tax for their accounting periods under the regulation need to submit a special tax return for the top-up tax. It is required that the top-up tax return should contain the information needed by the tax authority to determine the top-up tax and to complete the assessment of taxes. The Tax Administration will release further instructions later.
The return must be filed in MyTax within 15 months from the end of the consolidated entity’s accounting period. However, when filed for the first time, the due date is 18 months from the end of the accounting period. The first due date for the top-up tax return will be 30 June 2026.