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 entity 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.
Examples of filing
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Example 1: The accounting period of the group is calendar year. The group’s annual revenue according to the consolidated financial statements:
| Accounting period | Annual revenue |
|---|---|
| 2022 | €720 million |
| 2023 | €750 million |
| 2024 | €748 million |
| 2025 | €760 million |
The annual revenue was at least €750 million in 2023 and 2025, so the act on the minimum tax rate for large-scale groups is applied to the group from accounting period 2026 onwards. The first information returns must be filed within 18 months from the end of the accounting period, i.e. by 30 June 2028. The information returns for the next accounting period must be filed within 15 months from the end of the accounting period, i.e. by 31 March 2029.
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Example 2: What is the first due date of the GloBE information return when the accounting periods end on 31 March 2024 and 31 March 2025?
According to chapter 10, § 1 of the act on the minimum tax rate for large-scale corporate groups, the act entered into force on 1 January 2024 and is applied for the first time to accounting periods beginning on or after 31 December 2023. If the accounting periods of the example are 12 months, the accounting period that ended on 31 March 2024 had begun before the act started to be applied, so the act is applied for the first time to the accounting period that ended on 31 March 2025. When the information return is filed for the first time, the time limit is 18 months, so the first GloBE information return must be filed by 30 September 2026.
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Example 3: A foreign company has a permanent establishment in Finland. What information must be filed in Finland?
For purposes of minimum taxation, the permanent establishment is a constituent entity, which has an independent reporting obligation. If the foreign company or main operation files the GloBE information return (GIR) in its country of location, then the Finnish permanent establishment must file the notification of the filing constituent entity in MyTax.
If the GIR is filed in Finland, then no notification needs to be filed here. If the actual tax rate in Finland is less than 15%, then the top-up tax is taxed in Finland as domestic top-up tax. In that case, a top-up tax return must also be filed.
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Example 4: The group has entities in jurisdictions A, B, C and D.
- The Income Inclusion Rule (IIR) is not in force in the jurisdiction of the ultimate parent entity A1.
- B1 and B2 are located in Finland, the IIR and the Qualified Domestic Minimum Top-up Tax (QDMTT) are in force.
- B1 and B2 are required to submit reports to Finland.
The group can designate an entity to file the GloBE information return for the entire group. Information on all group entities must be given in the general section. Jurisdiction-specific information must be filed on jurisdictions B and C because B1 and B2 are not obliged to apply the IIR in the case of low taxation in C, nor the QDMTT in the case of low taxation in B. If the Undertaxed Profits Rule (UTPR) were in force in Finland, information should also be filed on jurisdictions A and D. This would also be the case if the QDMTT were in force in jurisdictions A and D.
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Example 5:
- Group’s ultimate parent entity A1 is located in jurisdiction A.
- Subsidiary entities B1 and B2 are located in Finland.
- The group’s GloBE information return is filed by A1.
In Finland, a notification must be filed in MyTax to specify the entity filing the GloBE information return and to submit identifying details (Business ID) on the Finnish entities. Only one notification is needed if it contains the information on both B1 and B2.
Because the domestic top-up tax complying with the QDMTT safe harbour requirements is in force in Finland, the domestic top-up tax calculations are reported in the section specific to the Finnish jurisdiction on the GloBE information return. No calculations are needed if the prerequisites for applying the safe harbour rule regarding the transition period of country-by-country reporting are met in Finland.
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Example 6: The group has entities in jurisdictions A, B and C.
- The ultimate parent entity is Finnish: the GloBE information return is filed in Finland, notifications are filed in other relevant countries.
- Information on all constituent entities is included in the general information.
- Jurisdiction-specific information is submitted on all the three jurisdictions.
- The information content regarding a jurisdiction depends on whether a safe harbour rule or an exemption is applicable.
- In jurisdiction B, a safe harbour rule is applicable, so information relevant to the rule is filed.
- In jurisdiction C, no safe harbour rule is applicable, so information needed to determine the actual tax rate and any top-up tax is filed.
- The Finnish constituent entity files a top-up tax return if it is required to pay top-up tax in Finland.
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