Minimum tax rate for large-scale groups (OECD Pillar Two)

CURRENT INFORMATION

At the beginning of June, the OECD published a new guidance on the XML schema of the GloBE information return (GIR): Guidance on the use of the GIR XML Schema for the first GloBE filing and exchange cycle (June 2026) (PDF). The guidance provides further guidance on reporting in certain situations. According to the guidance, some validation rules will also be removed.
Large-scale domestic groups must file a GloBE information return (GIR) in Finland even if the transitional provision on large-scale dometic groups is applied to them. The GIR does not include a separate section where the group could state that it is covered by the transitional provision. For more detailed information on the information to be reported, go to the Filing page and see "The filing of returns by a large-scale Finnish group during the transition period".
Central filing for 2024

The OECD has published a guideline to promote central filing: Common understanding of 2024 implementing jurisdictions to support Central GloBE Information Return Filing and Exchange. The guideline lists 33 countries for which central filing could be accepted within the limits of local legislation even if the information exchange relationships are not in effect by the filing deadline.

In Finland, however, legislation sets limits to central filing. Finland accepts central filing in other countries only if the information exchange relationships are in effect before the filing deadline expires, the GloBE information return (GIR) has been submitted within the time limit, and the notification has been submitted in Finland within the time limit.
EU: Cyprus’s minimum tax rate regulation is considered qualified

The EU has outlined that in the hierarchy of tax rules relating to top-up tax, Cyprus’s rules are ranked in the same position as rules that are considered qualified in the peer review process of the Inclusive Framework: Frequently Asked Question on Pillar 2 Directive: Cyprus IIR treatment 2024
The OECD has published an updated commentary that includes all guidance issued up to May 2026.
OECD has released a new version of the international standard regarding the content of the information return on top-up tax, GloBE Information Return (January 2025), and an XML schema that will be used in the reporting of information and in the exchange of information between authorities.
- Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January 2025) | OECD
- GloBE Information Return (Pillar Two) XML Schema | OECD (Click Download the XML Schema (ZIP))
If you have any questions, please send email to: Minimivero(a)vero.fi

General information about Pillar Two

The purpose of the minimum tax-rate for large-scale groups is to ensure minimum-level taxation around the world. The minimum tax rate applies to multinational groups whose annual income according to the consolidated financial statements exceeds €750 million during at least two of the four accounting periods immediately preceding the accounting period in question. In the EU area, the minimum tax rate also applies to large domestic groups.

Filing

Groups must file their returns and notifications within 15 months from the end of the accounting period. However, the first filing period is 18 months. Returns for accounting periods that ended in 2024 must be filed by 30 June 2026.

Late-filing penalty and punitive tax increase

If you file any of the above returns and notifications or any information included in them late, the Tax Administration may impose a late-filing penalty or a punitive tax increase on you.

Top-up tax

A constituent entity is obliged to pay top-up tax in Finland if the group’s effective tax rate in Finland is less than 15% during the accounting period, i.e. less than the minimum tax rate, or if top-up tax payable for the accounting period is allocated to the entity because of a low effective tax rate in another jurisdiction.

Appeals

A constituent entity may appeal against the Tax Administration’s top-up tax decision and separate decision (decisions on a late-filing penalty and punitive tax increase) by submitting a claim for adjustment to the Assessment Adjustment Board.