Global Daily Tax News, OECD Releases Pillar Two Return XML Schema And Guide, (Jul 15, 2024)

On July 10, 2024, the OECD released a Draft User Guide for the GloBE Information Return XML Schema for consultation.

The Global Anti-Base Erosion (GloBE) Model Rules require the annual filing of a GloBE Information Return (GIR) that provides information on the tax calculations made by an MNE Group under the GloBE Rules.

In July 2023, the BEPS Inclusive Framework agreed a standardized GIR template to be relied upon by all implementing jurisdictions, as well as an approach for disseminating the contents of the GIR amongst such implementing jurisdictions.

The Inclusive Framework has now released a draft version of the GIR XML Schema and a User Guide. These are intended to facilitate domestic GIR filings, wherever appropriate, as well as provide for the technical format for exchanging GIR information between tax administrations.

The GIR XML Schema is designed to be used for the exchange of information reported under the GIR between competent authorities that have activated exchange relationships under the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns (GIR MCAA), or another Qualifying Competent Authority Agreement.

The OECD said, where appropriate, jurisdictions could also consider using the schema domestically for the purpose of gathering the required information from their respective Filing Constituent Entities.

The GIR User Guide is said to be divided into logical sections based on the GIR XML Schema and provides information on specific data elements and any attributes that describe each data element.

The main sections of the GIR Schema User Guide are:

• The Message Header with the sender, recipient, message type, and Reporting Fiscal Year;

• The ID and TIN types, used for providing identifying and TIN information in relation to Constituent Entities, JVs, JV Subsidiaries, and UPEs; and

• The GloBE Body.