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A practical guide to the categories of filing obligations that in-scope multinational groups are navigating, and and how Orbitax keeps Pillar Two forms up to date.
Introduction
When the OECD/G20 Inclusive Framework published the Pillar 2 model rules, the compliance implications were clear in broad terms: a 15% effective minimum tax on the profits of multinational enterprise groups with annual revenues above EUR 750 million. What was less obvious at the outset was the administrative footprint that came with it.
As jurisdictions move from legislation to implementation, it is now clear that Pillar 2 is not a single filing obligation. It is a collection of them. Depending on where a group operates, it may face registration requirements, information return filings, top-up tax returns for multiple charging mechanisms, below-threshold notifications, and agent appointment procedures, across dozens of jurisdictions, often on different timelines and in different formats.
This article maps the distinct categories of GMT compliance forms now required across enacted jurisdictions, explains them, and addresses the practical challenge of keeping all of them current as legislation continues to change.
Why the Form Landscape Is More Complex Than It First Appears
The OECD published model rules and a standardised GloBE Information Return template. That standardisation has reduced fragmentation compared to earlier reporting frameworks. But standardisation at the model level has not produced uniformity at the jurisdictional level.
Several factors drive that divergence:
- Jurisdictions enact Pillar 2 on different timelines. Some jurisdictions were live from January 2024. Others are still in consultation or have not yet committed to a date. Each new enactment brings a new set of local forms.
- Domestic implementation choices vary. A jurisdiction that enacts a QDMTT will often require a separate domestic top-up-tax return. A jurisdiction that accepts centralized GIR filing will need a local notification form instead. These reflect structural differences in how jurisdictions have implemented the rules
- Filing formats are not uniform. Some jurisdictions accept a PDF return. Others require portal submission, XML or CSV upload, or machine-to-machine API transmission. The form and the filing format are separate concerns, but both need to be managed.
- Local amendments follow quickly. Jurisdictions that enacted rules in 2024 have already amended them. Safe harbor elections, simplified ETR calculations, and transitional provisions have all triggered form revisions that tax teams need to track.
The Core Categories of GMT Compliance Forms
Below is a taxonomy of the form types that in-scope groups are expected to manage. Not every jurisdiction requires every category. But across a typical large MNE footprint spanning Europe, Asia-Pacific, and the Americas, most groups will encounter all of them.
| Form Type | Purpose |
|---|---|
| Registration Forms | Establish the MNE group’s presence with local tax authorities and designate a filing entity before substantive returns are due. |
| GloBE Information Return (GIR) | The core Pillar 2 filing: discloses GloBE income, covered taxes, and effective tax rates by jurisdiction, and determines top-up tax liability. |
| GIR Notification Forms | Filed by constituent entities where centralized GIR filing in another jurisdiction satisfies the group’s reporting obligation, notifying the local authority accordingly. |
| QDMTT Return Forms | Standalone returns for jurisdictions levying a Qualified Domestic Minimum Top-up Tax on low-taxed local profits before cross-border top-up rules apply. |
| IIR Returns Forms | Returns for groups applying the Income Inclusion Rule to charge top-up tax on low-taxed constituent entity profits at the Ultimate Parent Entity level. |
| UTPR Return Forms | Returns for the Undertaxed Profits Rule, applied where neither the IIR nor a QDMTT has fully collected the required top-up tax. |
| Below-Threshold Notification Forms | Filed by groups that are technically in scope but fall below local activation thresholds, or that elect simplified computation options. |
| Self-Assessment / Payment Forms | Combine the tax calculation and payment instruction in a single submission, common in civil law jurisdictions with integrated payment systems. |
| Agent & DFE Appointment | Procedural forms used to appoint a tax agent, designate a filing entity, or substitute an existing Designated Filing Entity (DFE). |
The table above reflects the current state of implementation across enacted jurisdictions. As more countries move from legislation to active filing requirements, more form types may be introduced.
A Closer Look at the Key Forms
The GloBE Information Return
The GIR is the anchor document in any Pillar 2 compliance programme. It reports the group’s GloBE income, covered taxes, and effective tax rate on a jurisdiction-by-jurisdiction basis. It also calculates any top-up tax liability before local charging rules are applied.
The OECD has published a standardised GIR template consisting of an xsd schema (the set of strict technical rules about how the form must look) and a PDF for visualization.Many jurisdictions are using this xsd schema directly. But a number of jurisdictions have introduced local variants with additional data requirements, different section ordering, or supplemental schedules. Groups with entities in multiple enacted jurisdictions may need to track several GIR variants simultaneously, on top of the standardised return.
The GIR filing deadline varies by jurisdiction but is typically 15 to 18 months after the close of the fiscal year in question. For most groups, FY2024 GIRs will be due on June 30. FY2025 GIRs will follow in early 2027. These deadlines are generally fixed, with limited scope for extension depending on jurisdiction..
QDMTT, IIR, and UTPR Returns
The three top-up tax mechanisms operate in sequence. The QDMTT has first priority. Where a jurisdiction levies its own domestic minimum tax on undertaxed profits, it collects that tax before another jurisdiction can apply the IIR or UTPR. Jurisdictions that enact a QDMTT also tend to require a separate QDMTT return, distinct from the GIR.
The IIR applies at the Ultimate Parent Entity level and taxes the parent on its proportionate share of undertaxed profits in any jurisdiction where the QDMTT threshold has not been met. The UTPR operates as a backstop, distributing any remaining top-up tax across jurisdictions based on headcount and asset metrics, where neither the QDMTT nor the IIR has fully captured the required amount.
Each mechanism can generate its own return requirement. A group operating in a jurisdiction with all three charging mechanisms may be required to file a QDMTT return, an IIR return, and a UTPR return, in addition to the GIR and any applicable notification or registration forms.
Below-Threshold and Notification Forms
Not every in-scope group will owe top-up tax in every jurisdiction. Groups that fall below local effective tax rate thresholds, or that qualify for one of the transitional or permanent safe harbors, may be exempt from substantive top-up-tax returns for a given period. But exemption from the tax does not mean exemption from filing. Most jurisdictions require a notification or below-threshold declaration to confirm the safe harbor position or threshold test. These forms are often shorter, but they are just as time-sensitive.
What This Means for In-House Tax Teams
For most in-house teams, the practical implication of this landscape is straightforward: the manual effort required to track and maintain Pillar 2 forms across a broad jurisdictional footprint is not sustainable. The volume is too high, the change frequency is too fast, and the consequences of filing on a superseded form version are too significant to treat this as a background task.
Teams approaching this well are typically doing a few things consistently:
- Mapping their full filing obligation set before the season begins, not just the jurisdictions where they expect top-up-tax exposure. Registration and notification obligations apply even where no tax is owed.
- Building a clear record of which form version applies to which fiscal year for each jurisdiction, and keeping it updated as versions change.
- Identifying early which jurisdictions require machine-to-machine or API-based filing and ensuring the technical infrastructure for those transmissions is tested well ahead of the deadline.
- Treating the GIR as foundational. Even groups that qualify for safe harbors in a given year are in most cases still required to file a GIR. Safe harbors reduce the tax, they do not eliminate the filing.
- Planning for amendment cycles. First-year GIR filings will almost certainly require amendment as interpretive guidance matures and groups refine their GloBE calculations. The forms infrastructure needs to support that process, not just the initial submission.
The groups that are managing this most effectively are those that have moved away from spreadsheet-based form tracking and toward a structured compliance workflow where form currency, deadline management, and data population are handled systematically. The investment in getting that infrastructure right in FY2024 pays off compounding dividends as the number of enacted jurisdictions grows.
How Orbitax Supports Form Management at Scale
Keeping Pillar Two forms accurate is not a one-time task but an ongoing process, as OECD guidance evolves, jurisdictions amend local rules, and tax authorities update formats and filing requirements throughout the year. Orbitax is designed to support this continuous change through a structured approach that combines legislative monitoring, version control, and workflow integration. Changes in rules and forms are incorporated into a review process to assess their impact, while forms are version-controlled with effective dating so teams can align the correct version to the relevant fiscal year or filing period. A structured classification framework across form types, jurisdictions, and filing mechanisms helps surface the appropriate forms within the compliance workflow, rather than relying on manual tracking. Forms and updates are subject to expert review, including validation of data mapping to GloBE concepts and alignment with enacted rules and available guidance. Within this framework, the Orbitax Filing Manager supports a broad and growing library of Pillar Two forms across multiple jurisdictions and filing categories, helping tax teams manage form selection, currency, and population as part of a more systematic compliance process.
Conclusion
Pillar 2 has added a substantial new layer to the international tax compliance calendar. The form types are relatively fixed, but the forms themselves keep changing. Jurisdictions continue to amend rules, revise templates, and introduce new filing format requirements as implementation matures.
Understanding the full taxonomy of what needs to be filed is the starting point. Keeping those filings accurate, on the right version, in the right format, across every jurisdiction in scope is the ongoing work. For many tax teams, this is difficult to sustain through manual processes alone, particularly in an environment already constrained by limited resources and increasing compliance demands.
As a result, form management is becoming more closely tied to broader tax technology strategy. Structured workflows, centralized form libraries, and integrated data mapping are increasingly important to help teams stay current and reduce risk. Solutions such as Orbitax are designed to support this shift by combining form tracking, version control, and filing workflows within a single environment, allowing tax teams to manage change more systematically as part of their day-to-day compliance process.
The landscape will not simplify in the near term. More jurisdictions are enacting legislation. More are moving to automatic transmission. Teams that are best positioned are those that combine a clear understanding of filing obligations with the right processes and supporting technology to stay aligned as requirements continue to change. To see the complete list of forms available, check here.*
*All of these forms can be purchased on its own through our marketplace or they are all included in the full GMT license along with calculations, reporting and direct transmission (where applicable).
If you are evaluating how to structure your Pillar Two filing workflow, we are happy to share what we are seeing across jurisdictions and filing types. Book a meeting with us.
This article reflects the current state of Pillar Two implementation based on enacted legislation and publicly available guidance as of 28 April, 2026. Requirements may continue to evolve.