OrbitaxWhat the First GIR Cycle Taught Us, and How to Prepare for the Next: Insights from Orbitax and WTS
For most multinational groups, June 2026 brought the first GloBE Information Return (GIR) filings under Pillar Two, prepared with no prior-year return to work from, no established playbook, and local requirements that in several jurisdictions were published close to the filing window. Orbitax and WTS worked together through that cycle, supporting more than 100 groups, including several listed multinationals, through preparation, review and submission.
A completed calculation was not a completed return
The GIR works more like a structured data exchange than a conventional tax filing. The OECD schema defines what must be present, how sections relate to one another and which combinations of values hold together, and each jurisdiction layers its own fields, validation rules and transmission requirements on top. To meet both, teams had to assemble entity and ownership data, agree entity classifications and convert their calculations into a valid submission file. Much of that data, from in-scope entity lists to ownership percentages and mid-year structural changes, sat with group reporting, legal and systems teams rather than with tax.
Across the Orbitax platform, more than 1,700 Pillar Two filings were prepared or submitted between November 2025 and June 2026 across 34 jurisdictions. Returns supported jointly by Orbitax and WTS were filed ahead of the deadline through direct electronic transmission to the German, Dutch and UK tax authorities, with acceptance confirmed in all three.
Where the effort went
Five areas accounted for much of the preparation and filing work. Pillar Two scoping came first: confirming the entity population and ownership relationships, then classifying each entity under the Pillar Two rules. Late changes here were more disruptive than late changes to any number, because they reached into several schedules at once. Transitional CbCR Safe Harbor reporting followed, assessed on a jurisdictional ETR group basis that differs from the grouping used for the top-up tax calculation. For groups with thirty or forty jurisdictions, it became a project in its own right.
The step that surprised most teams was turning populated schedules into a valid submission file. A return could be arithmetically correct and still fail validation because of an unresolved section reference, an inconsistency between the jurisdictions with taxing rights and those receiving the information, a local field the base schema does not require, or a figure entered in the wrong decimal convention. Alongside this, certificates, sender registration and third-party authorizations had to be prepared separately for each jurisdiction, often with external lead times. Submission did not end the process either. First-season rejections were common, mostly structural rather than substantive, and acceptance often came on a second pass after correction.
Why it matters
Groups that addressed these tasks early had time left for final review and sign-off. Those that left them until June were resolving data, validation and registration issues as the deadline approached. Close to a third of all filing activity happened in the final week before 30 June, and most of that week went on review, approval, local filing steps and validation rather than on the computation itself.
The cycle also clarified how to organize multi-jurisdiction filing. Entity data, classifications and calculations can run through one group-wide preparation process, while local validation, credentials, submission channels and authority responses each need a separate plan per jurisdiction. The GIR was also the smaller part of the obligation, with over 60 percent of filing activity on the platform made up of notifications and self-assessment returns, alongside QDMTT returns and registrations.
Preparing for FY2025
The next GIR deadline is 31 March 2027 for fiscal year 2025. Nearly all the work that consumed time in the first cycle can be done earlier, and much of it does not depend on the return being finished. Certificates, sender registration and authority to submit can be arranged for each jurisdiction in Q4 2026, well before final review begins. Most importantly, teams should generate and validate a complete test submission in January or February 2027, since the structural issues that caused trouble in the first cycle only surface once a file exists.
“If there is one piece of advice for groups preparing for the FY2025 filing, it is to start as early as possible, ideally now. The first cycle showed that having entity master data refreshed, CbCR data processed and the key scoping decisions settled well before year-end makes a significant difference, particularly with a 31 March 2027 deadline coming so soon after the financial close. The more that can be completed during 2026, the more the final weeks can be reserved for review, sign-off and submission rather than fundamental preparation.”
Senior Manager, Digital Income Tax & Reporting, WTS
Read the full whitepaper
The First GloBE Information Return covers each of these areas in detail, with practical takeaways, an indicative FY2025 preparation timeline and further commentary from WTS. To read the full whitepaper, download it here.