M
aking D
ispute Resolution M
ore Eff
ective – Sim
plifi
ed Peer Review
, Burkina Faso (Stage 1)
O
ECD/G20 Base Erosion and
Profit Shifting Project
OECD Forum on Tax Administration
The Global Minimum Tax
Implementation Toolkit
Global Minimum Tax Implementation Toolkit
PUBE
2
This work was approved and declassified by the OECD Committee on Fiscal Affairs on 22 April 2026.
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Please cite this publication as:
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Acknowledgments
The project was funded by the European Union via the Technical Support Instrument, and implemented
by the OECD, in co-operation with the European Commission. The work also benefited from financial
support by other contributors.
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Table of contents
Acknowledgments 3
Introduction 6
Module 1. Assessing in-scope MNE groups and revenue 12
Introduction 12
. Using CbC reports to estimate the population of in-scope MNE Groups in a
jurisdiction 13
. Commercial datasets 20
. Other sources of data to estimate in-scope population 24
. Estimating top-up tax revenue 28
Module 2. Legal Implementation 34
Introduction 34
. Legislative techniques 36
Legislative techniques for updating domestic law 42
. Interpretation mechanisms 46
Module 3. Organising and Planning for the Implementation of the GMT 49
Introduction 49
. Implementation plan 49
. Assessing key tax administration functions and need for changes 51
Module 4. Framework on Compliance Procedures 68
Introduction 68
GMT Compliance procedures and best practices 69
Module 5. Exchange of Information 85
Introduction 85
. Legal implementation of the exchange of information under the GloBE Rules 86
. Operational implementation of exchange of information of the GIR 91
FIGURES
Figure 1. The GMT implementation roadmap 11
Figure 2. Applying filters to aggregated CbC reporting data in the OECD Data Explorer 25
Figure 3. Estimating the number of in-scope MNE groups by UPE jurisdiction using aggregated CbC reporting
data 26
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Figure 4. Calculation of top-up taxes under GloBE 28
Figure 5. External communication objectives and channels 60
Figure 6. IT Functionalities for GMT Compliance 61
Figure 7. Key Steps of the GMT Compliance Procedures 69
TABLES
Table 1. Ownership data from Orbis is relatively complete 21
Table 2. Key data scenarios and recommended data sources 29
Table 3. Comparison of ambulatory and static approach of cross-reference 39
Table 4. Overview of the key tax administration functions 52
Table 5. Dissemination approach for the General Section 94
Table 6. Dissemination approach for the Jurisdictional Section(s) 95
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Introduction
1. The Global Minimum Tax (GMT) agreed in 2021 by the Inclusive Framework on BEPS (IF) consists
of a coordinated set of rules - the Global Anti-Base Erosion (GloBE) Rules1, as complemented by a
Commentary and Administrative Guidance2 - designed to ensure that large multinational enterprises
(MNE) are subject to a minimum level of tax in each jurisdiction where they operate. Where the level of tax
is below the agreed minimum, the top-up tax is either collected by the low-tax jurisdiction itself, under a so
called Qualified Domestic Minimum Top-up Tax (QDMTT), or, where no QDMTT applies, by another
implementing jurisdiction through the imposition of either:
a. an Income Inclusion Rule (IIR) which imposes top-up tax on a parent entity in respect of the low
taxed income of a constituent entity; or
b. a UTPR which denies deductions or requires an equivalent adjustment in a subsidiary jurisdiction
in order to produce an equivalent incremental increase on the taxes paid by the MNE Group.
2. The rules also include agreed safe harbours that provide relief either by means of simplification or
deemed top-up tax of zero in a given jurisdiction to the MNE Groups when conditions for specific safe
harbour are met. Jurisdictions deciding to adopt these rules – in whole or in part – implement them in their
domestic law and, in doing so, recognise the safe harbours and the qualified GMT rules of other
jurisdictions in line with the agreed rule
3. To date, over 60 jurisdictions have already implemented the rules, while many others are in the
process of evaluating or preparing for implementation. While the domestic tax system of each
implementing jurisdictions may differ, many implementing jurisdictions have confronted similar issues when
transposing the GMT into their tax system. The existence of common challenges highlights the benefits
from common and coordinated approaches. These shared challenges and opportunities were first
acknowledged by the Forum on Tax Administration through the Large Business International Programme
(LBIP) which extended an invitation to tax administrations from Inclusive Framework countries to a kick-off
event in Amsterdam in October 2024 to discuss GMT implementation and compliance issues. The event
was open to all IF members and attended by close to 70 tax administrations, along with business,
1
For further details on the GloBE Rules, see:
2
OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the
Global Anti-Base Erosion Model Rules (2025): Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit
Shifting Project, OECD Publishing, Paris,
issues/global-minimum-tax/
3
The rule order entails that the application of the GMT rules in one jurisdiction (say the IIR in the jurisdiction of a
Parent Entity) is deactivated where they are qualified GMT rules applicable in another jurisdiction that take priority (say
the QDMTT Safe Harbour in the jurisdiction of the low-taxed Entity). To achieve this outcome, each implementing
jurisdiction need to have a common transparent basis for recognising qualified rules in another jurisdiction in a timely
fashion.
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
academics and other stakeholders. The participants at this meeting emphasised the importance of
increased and continued dialogue and collaboration on compliance approaches that deliver on the policy
goals of the GMT in a way that minimises compliance cost and complexity for both taxpayers and tax
administrations.
4. Following this meeting, the FTA endorsed the idea of a structured dialogue through the LBIP that
would engage with IF members and seek inputs from external stakeholders (hereafter, the “Amsterdam
Dialogue”). While all IF members were invited to input into the discussions, the dialogue focussed on three
priority areas of particular interest to implementing jurisdictions: (i) upfront compliance, (ii) co-ordinated
risk assessment, including systems-based approaches where appropriate, and (iii) dispute prevention and
resolution. In addition, discussions emphasised the importance of ensuring tax certainty and consistency
while reducing compliance burdens so to help jurisdictions that are implementing the GMT. The FTA
agreed to continue the Amsterdam Dialogue to advance on these goals and endorsed the delivery of a
common framework on upfront compliance as well as development of a co-ordinated risk assessment
framework to support consistent, risk-based and effective
5. The Global Minimum Tax Implementation Toolkit (the “Toolkit”) addresses the first of these two
aspects. Its objective is to assist jurisdictions that have already implemented the rules or have decided to
implement the rules with establishing a robust and efficient domestic compliance framework – the
combination of rules, procedures, and practices that support the collection and enforcement of the top-up
tax, including IT systems as well as practical and organisational considerations. It draws on the
experiences of those jurisdictions further advanced in the implementation journey, includes input from the
business and wider stakeholder community and seeks to identify best practices. These best practices are
meant to serve as guidelines for implementing jurisdictions in the design their administrative framework
and not to set standards. This Toolkit is an important element within the wider approach designed to deliver
on the status of the GloBE rules as a common approach. The concept of the common approach is intended
to ensure that those jurisdictions that proceed with implementation do so in a way that brings consistency
and coordination in the application of the rules across different jurisdictions. At the same time these best
practices have primarily been drawn from jurisdictions that were early adopters of the GMT and may not
always translate into the specific context of all implementing jurisdictions, particularly those of developing
6. As part of the wider efforts to ensure consistency and coordination in the application of the GloBE
Rules across different jurisdictions, the IF agreed to establish a peer review process. This process
provides a common framework for assessing and recognising the “qualified” status of the IIR, UTPR and/or
QDMTT (including eligibility for the QDMTT Safe Harbour), based on a full legislative review and an
4
Statement of outcomes: Forum on Tax Administration Plenary 2025.
.
5
The OECD has developed an extensive capacity building programme to support developing countries in
understanding the GloBE rules, how they interact with existing tax incentives, and in analysing the appropriate policy
choices in the context of a comprehensive programme of support on international tax (see
for an overview of the OECD’s work on tax and
development). The OECD’s Global Relations Programme on Tax (
) provides in-person and virtual multilateral training, recorded webinars and self-
paced e-learning resources on the GloBE rules. Bilateral assistance to support implementation of the GloBE rules is
also available through the OECD/UNDP Tax Inspectors Without Borders initiative (). To assist tax
policy and administration officials with considering whether or not to adopt the GMT, including assessing different
implementation options, a separate Implementation Handbook is available (see OECD (2023), Minimum Tax
Implementation Handbook (Pillar Two), OECD/G20 Base Erosion and Profit Shifting Project, OECD, Paris,
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
ongoing monitoring process of each jurisdiction that implements the In addition, the IF has adopted
a transitional mechanism allowing the timely recognition of the qualified status of an implementing
jurisdiction’s legislation on a temporary basis. This transitional approach relies on self-certification by the
implementing jurisdiction, supported by a high-level review of its domestic legislation. Jurisdictions that
qualify under this process are then recorded in a central record of jurisdictions with qualified status. This
central record is maintained and regularly updated on the OECD A central record of qualified
rules provides certainty to MNE Groups and reduces risks of double or over-taxation while allowing time
for the full legislative review to be undertaken.
7. In parallel, the IF has also taken several initiatives to support a consistent and coordinated
approach to the administration of the GMT rules, particularly in relation to the collection and exchange of
taxpayer information. Key initiatives include:
• Common rules for the collection of GloBE information through the GloBE Information Return
(GIR)8. The GloBE rules impose, by default, on each Constituent Entity of an in-scope MNE Group,
an obligation to file the GIR with the tax administration of the jurisdiction where it is located. This
local filing obligation, however, is switched off if the GIR is centrally filed in the jurisdiction of the
Ultimate Parent Entity (UPE) or the Designated Filing Entity (DFE) and the Competent Authority of
that jurisdiction has entered into a bilateral or multilateral agreement or arrangement in effect to
automatically exchange the GIR with the Competent Authority of the jurisdiction of another
Constituent Entity.
• The standardised template for the GIR released in July 2023, and updated in January 2025,9
which has been designed to provide each implementing jurisdiction with access to the information
they need to perform an appropriate risk assessment and to verify the calculation of an MNE
Group’s GMT liability in a given jurisdiction. The GIR template specifies all data elements
necessary to verify the correctness of a GMT liability, specific rules ensuring that each jurisdiction
receives only the portions of the GIR that is relevant for the application of their own GMT rules,
consistent with the MNE Group’s structure, the rule order and the agreed dissemination
• The Multilateral Competent Authority Agreement on the Exchange of GloBE Information
(GIR MCAA) released in January The GIR MCAA provides a framework for the central
6
The legislative review will determine if the legislation of an implementing jurisdiction achieves consistent outcomes
with those provided for under the GloBE Rules. The ongoing monitoring will review if the rules are being applied and
administered consistently with the GloBE Rules, and that an implementing jurisdiction does not provide benefits which
are related to the GloBE Rules. The terms of references that will serve as a basis for these reviews are currently under
development.
7
See:
8
As provided for Article 8 of the MR, released in 2021.
9
OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – GloBE Information Return (January
2025): Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris,
Note that the standardised template for the GIR may be modified in the future to
accommodate future changes agreed by the IF members.
10
The dissemination approach agreed by the IF ensures that implementing jurisdictions can collect or access the
information they need depending on their specific situation in relation to each MNE Group that is subject to the rules
in their jurisdiction.
11
OECD (2025), Tax Challenges Arising from the Digitalisation of the Economy – Multilateral Competent Authority
Agreement on the Exchange of GloBE Information (January 2025), OECD/G20 Inclusive Framework on BEPS, OECD,
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
filing of the GIR with a single tax administration and the subsequent exchange with the other tax
administrations. It sets out the detailed modalities for the exchange to take place on an automatic
basis, including the confidentiality and data safeguards that must be A list of the
jurisdictions that signed the GIR MCAA is available on the OECD As an alternative,
jurisdictions may also conclude a bilateral Competent Authority Agreement that is based on the
Convention, a Tax Information Exchange Agreement, a Tax Treaty with a provision equivalent to
Article 26 of the OECD Model Tax Convention or any other international agreement that allows
automatic exchange of information.
• The GIR XML Schema and corresponding User Guide released in January 2025 to support the
automatic exchange of the GIR between tax This XML Schema translates the
GIR standardised template into a common schema of extensible mark-up language to allow for this
information to be reported and exchanged in a single Information Technology (IT)-format. Designed
primarily to facilitate exchange of the GIR when filed centrally in the jurisdiction of the UPE or DFE
of the MNE Group, it is also intended to be used to facilitate the local filing of the GIR.
• The GIR Status Message XML Schema (incl. common validation rules) released in July 202515
to improve the quality and consistency of data exchanged through the GIR XML Schema. Since
the data transmitted via the XML Schema may contain errors, such as those arising from incorrect
file preparation or incomplete or inaccurate records, the common status message XML is a
template allowing tax administrations to report such errors in a structured manner to the sending
tax administration. It can also be used by a tax administration to provide a status message to its
domestic filing Constituent Entities. It also includes the list of agreed file and record validation rules
to be checked for the purpose of identifying errors in the GIR filing.
These initiatives are standards agreed by the IF that together form the basis of the common approach.
The work undertaken in the context of the Amsterdam Dialogue does not impact on these standards.
Rather, it seeks to assist tax administrations with applying these standards in a consistent and co-ordinated
way.
The Global Minimum Tax Implementation Toolkit
8. Once a jurisdiction has made a decision to adopt all or part of the GMT, the subsequent steps
required to implement the domestic rules and prepare for their effective administration are specific to each
implementing jurisdiction. While the content of the implementation will necessarily be specific to each
jurisdiction, and tailored to its needs, its development generally relies on assessments and methods that
are common across several jurisdictions. At the same time, experience shared through the Amsterdam
Dialogue shows that tax administrations face many of the same challenges when integrating the GMT into
their domestic compliance framework and preparing for the first filing requirements and payment deadlines.
The discussions in the Amsterdam Dialogue underlined the value of developing common guidelines and
best practices to support tax administrations in this process, which
Paris,
.
12
The GIR MCAA is based on Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters (the
Convention).
13
See the public record of the signatories list :
transparency-and-international-co-operation/
14
OECD (2025), GloBE Information Return (Pillar Two) XML Schema: User Guide for Tax Administrations, OECD
Publishing, Paris,
15
OECD (2025), GloBE Information Return (Pillar Two) Status Message XML Schema: User Guide for Tax
Administrations, OECD Publishing, Paris,
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
• draw on the practical experience of early adopters;
• clarify key aspects of the GMT implementation for tax administrations, including timelines and
milestones;
• help identify and address common challenges; and
• promote consistency and coordination across jurisdictions through best practices, thereby reducing
compliance and administrative burden for both tax administrations and taxpayers.
9. In response to this need, the Toolkit has been structured as a roadmap setting out the key steps
and actions that tax administrations commonly undertake to implement the GMT. This roadmap is intended
to serve as a model and practical reference guide that tax administrations can adapt to their specific legal,
administrative, and operational contexts. To help with organisational aspects and clarify possible timelines,
the Toolkit is structured around an implementation roadmap broken down into two phases:
• A pre-Implementation phase - Once a jurisdiction has decided to adopt all or part of the GMT,
the first step for the tax administration is usually to assess and identify what changes and new
features are needed to establish a robust and efficient compliance framework ahead of the first
filing and payment This is a planning exercise that typically involves:
o Estimating the number of in-scope MNEs and potential revenue (Module 1); and
o Assessing the implications of how the GMT is (or will be) incorporated into domestic legislation
(Module 2).
• An implementation phase - Building on the GMT implementation choices, the next step for the
tax administration is usually to execute its different elements so that the compliance framework is
fully operational by the first filing and payment deadlines. This usually involves:
o Developing a GMT implementation plan with a timeline, costs, budget, introducing
organisational and IT changes, and rolling out a communication strategy (Module 3);
o Designing and operationalising compliance procedures that support collection of the top-up tax
(Module 4); and
o Leveraging opportunities offered by international cooperation in order to receive the necessary
information to risk assess the top-up tax due, in particular the automatic exchange of the GIR
(Module 5).
10. The Toolkit seeks to provide a comprehensive description of the GMT implementation process
that is usually carried out by tax administrations, spanning from the initial assessment of impact and legal
implementation of the rules to the collection and administration of the top-up tax (see below Figure 1).
16
In some jurisdictions, tax administrations are also involved in the legislative process that leads to the incorporation
of the GMT rules into domestic legislation. This role however varies significantly across jurisdictions, including in some
jurisdictions no or a very limited role for tax administrations.
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Figure 1. The GMT implementation roadmap
11. The Toolkit is broken down into separate (but complementary) modules, with each module
dedicated to a specific stage of the implementation process. This modular approach should allow tax
administrations to use the Toolkit in a way that best fits their context and needs, including where relevant
by using only selected modules independently from the others.
12. It is intended for use by tax administration and tax policy officials but could also be useful for other
stakeholders involved in the application of the GMT rules. While this Toolkit builds on the GloBE Model
Rules and other standards agreed by the IF, it does not interpret or modify the application or interpretation
of these standards and the guidelines set out in this toolkit should only be used and applied in a manner
consistent with those standards.
13. The Toolkit may undergo occasional updates to reflect further progress and findings, as
implementing jurisdictions continue to gain more experience from the application of (and compliance with)
the GMT rules. It does not cover ongoing work with respect to risk assessment and verification approaches
nor coordination mechanism for addressing potential disputes.
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Key observations on assessing in-scope MNE Groups and revenue estimates
Based on the discussions held in the context of the Amsterdam Dialogue, this Toolkit includes the
following key observations on assessing in-scope MNE Groups and revenue estimates for GMT
implementation:
• CbC reports are best suited to estimating in-scope taxpayers for upfront compliance, subject to
the requirement for the appropriate use of CbC reporting data set out in the BEPS Action 13
report.
• However, some jurisdictions may wish to use commercial data to validate identification of in-
scope MNE Groups using CbC reports, or as an alternative if CbC reporting data is not available.
• If neither CbC reports nor commercial data are available, further alternatives for assessing in-
scope MNE Groups include using existing tax administration information, aggregated CbC
reporting data published by the OECD or a registration procedure for in-scope MNE Groups.
• Information on the identified in-scope MNE Groups can be used for top-up tax estimates as part
of an economic impact assessment.
• Details of key steps and adjustments in forthcoming OECD-World Bank document: “Estimating
QDMTT revenue using firm-level data: a practical guide”.
Introduction
14. This module provides considerations and recommendations on identification of in-scope MNE
groups and assessment of GMT revenue. Where a jurisdiction includes wholly domestic groups within the
scope of its GMT rules, the content of this module may also be applied to identify these in-scope groups
with appropriate adjustments (. a wholly domestic group will not be required to prepare and file a
country-by-country (CbC) report).
15. When a jurisdiction is in the process of introducing the GMT there are a number of benefits in
having a reasonably accurate estimate of the population of MNE Groups that are likely to be in scope of
rules in that jurisdiction. First, the GMT requires an infrastructure for the receipt and handling of GIRs that
needs to be designed and implemented or adapted from that which currently exists. Other modules in this
Toolkit cover different elements of this infrastructure, but across all of these elements an understanding of
the likely scale of the in-scope population is important to ensure the readiness of the tax administration in
advance of the first filing deadline.
16. Second, a broad understanding of the MNE groups that are most likely to be subject to the GMT
will help a tax administration in communicating with in-scope entities to promote an awareness of their
Module 1. Assessing in-scope MNE
groups and revenue
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
obligations under the GMT (. GMT filing and payment obligations/deadlines) and an understanding of
how these can be met in that jurisdiction (. the mechanics for how the GIR should be filed, or notification
given where a GIR will be filed by another group member in a different jurisdiction). This can promote
voluntary compliance with rules by ensuring local Constituent Entities in an MNE Group understand how
the GMT will operate in their jurisdiction, as well as by putting a Constituent Entity on notice that the filing
of a GIR is expected if the MNE Group is ultimately within the scope of rules for a period.
17. Third, an understanding of the likely in-scope population supports the estimation of the tax revenue
that may be raised under the GMT. Identifying MNE Groups and entities likely to fall within the scope of
the GMT represents an initial step in estimating potential GMT revenue using entity-level data. Subsequent
steps involve estimating the amount and nature of low-taxed profits in a jurisdiction, estimating potential
top-up tax revenue, and analysing the extent to which low-taxed outcomes are driven by the use of tax
incentives. Estimating the potential tax revenue that is likely to be levied under the GMT can assist
jurisdictions in evaluating likely impacts on their economies and in considering appropriate domestic policy
responses.
18. However, while each of these drivers for an understanding of the in-scope population are
important, they can all be achieved where a tax administration has a reasonably accurate estimate of that
population. A precise knowledge of exactly which local taxpayers will and will not be members of MNE
Groups that are in-scope of rules in advance may not be needed, and there may also be specific aspects
of rules (. concerning particular categories of Constituent Entities in MNE Groups) where a tax
administration may consider it more efficient and effective to leave until after GIRs are filed in order to
assess compliance in light of the additional data they provide. A tax administration should therefore
consider how accurate an estimate is needed for its intended purpose, and weigh this against the additional
burden on the tax administration itself from undertaking the process for a very detailed estimate and on
MNE Groups if they are required to undertake any additional compliance steps.
19. Whether a tax administration determines it requires a detailed understanding of the specific MNE
Groups likely to be in scope of the GMT in its jurisdiction, or only a high-level estimate of the size of the in-
scope population, different data sources may be leveraged to achieve this. In particular, where a tax
administration has access to CbC reports prepared and filed in accordance with BEPS Action 13, and/or
reliable commercial datasets such as Orbis, these can be a valuable source of information, either used
alone or together, and this module explores several ways in which this data can be used. However, data
availability differs between jurisdictions, and where neither of these sources are available to a tax
administration, there are other sources, such as aggregated CbC reporting data, consolidated financial
statements and pre-filing registration requirements, that can be used which can still provide a useful
estimate.
20. The estimation of potential top-up taxation is not covered here in detail but is discussed in a
forthcoming paper (OECD-World Bank, forthcoming). This module also does not consider steps that may
be taken by tax administrations after the GIR filing deadline to identify instances of non-compliance with
GloBE rules, which will be covered in later work on a risk assessment framework for the GMT.
. Using CbC reports to estimate the population of in-scope MNE Groups in a
jurisdiction
21. To date, CbC reports have been the source of data used most frequently by tax administrations
when attempting to estimate the number of MNE Groups likely to be in scope of the GMT in their jurisdiction
as well as to identify specific in-scope MNE Groups. This section considers the advantages of CbC reports
as a source of data for this exercise, as well as a number of challenges that they pose. It also describes
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
two approaches to the use of CbC reports that a tax administration can take, depending upon the level of
detail and specificity required.
. The advantages of using CbC reports
22. CbC reports offer a number of advantages as a data source for estimating the population of MNE
Groups that are likely to be in scope of a jurisdictions GMT.
Similarity in thresholds under BEPS Action 13 and Pillar 2
23. Both CbC reporting under BEPS Action 13 and the GMT apply a revenue threshold of EUR 750
million. Although differences in the application of these revenue thresholds mean that the population of in-
scope MNE Groups for the GMT may not be precisely the same as those for CbC reporting (see section
), in many cases if an MNE Group is in scope of CbC reporting it can be assumed it is reasonably
likely that the MNE Group will also be in scope of the GMT for the same period without undertaking further
work. This is particularly the case where a EUR-denominated threshold applies to the MNE Group for CbC
reporting purposes. As such, using CbC reports to estimate an in-scope population can be a relatively
straight-forward exercise. Approaches to undertake such an exercise, and some exceptions where further
work could be needed to obtain a more precise estimate, are discussed below.
Information on the Ultimate Parent Entity and the MNE Group’s reporting period contained
in CbC reports
24. Where a particular MNE Group is considered likely to be in scope of the GMT based on its CbC
reports, these CbC reports will also provide information on the MNE Group’s Ultimate Parent Entity (UPE),
including where it is resident for tax purposes. This can be useful for the tax administration in another
jurisdiction to understand which, if any, of its jurisdiction’s GMT rules may apply. For example, if the UPE
is resident in a jurisdiction that applies a Qualified IIR, or if the Side-by-Side (SbS) Safe Harbour is available
(which can quickly and easily be confirmed by cross-checking the jurisdiction where the UPE is resident
against the published list of jurisdictions that have an eligible system), then an IIR or UTPR in other
jurisdictions will not apply. On the other hand, if the UPE is resident in a jurisdiction that does not apply a
QIIR, and that does not have an eligible system for the purposes of the (SbS) Safe Harbour, then local
entities or Permanent Establishments (PEs) of the MNE Group resident in another jurisdiction could be
subject to the IIR or UTPR in that jurisdiction, should the conditions for those rules to apply be met. All
MNE Groups, including those subject to a QIIR or eligible for the SbS Safe Harbour, remain subject to the
QDMTT in all QDMTT jurisdictions in which they operate.
25. The SbS Safe Harbour provides a mechanism for recognising cases when an MNE Group is
headquartered in a jurisdiction with a tax system that imposes minimum tax requirements with respect to
domestic and foreign income. The Safe Harbour operates to switch off the application of a jurisdiction’s IIR
and UTPR where the UPE of an MNE group is located in a jurisdiction that has been listed in the Central
Record as having met the conditions of an eligible regime.
26. An MNE Group’s CbC report also includes the reporting year end of the UPE of the group. This
can be helpful in understanding when a GIR is due to be filed on an MNE Group, as under rules for the
GMT this filing deadline is linked to the year-end of the UPE of the MNE Group, which may be different to
year-end of entities in the tax administration’s jurisdiction.
27. It is important to note, however, that since all of this information is derived from prior-year CbC
reports, it may not be fully accurate (. if there have been subsequent changes to the MNE Group) but
would still be useful for a tax administration’s planning purposes.
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GLOBAL MINIMUM TAX IMPLEMENTATION TOOLKIT © OECD 2026
Information on local Constituent Entities
28. In addition to providing information on the UPE of an MNE Group, the CbC reports of an MNE
Group likely to be in-scope of the GMT will also provide information on the MNE Group’s Constituent
Entities in each jurisdiction where it has operations. This is useful for the purposes of determining which
local entities or PEs may be subject to the GMT in a particular jurisdiction (. those in the jurisdiction of
the tax administration undertaking the review).
Ease of availability of CbC reports in many jurisdictions
29. CbC reporting has been widely adopted by members of the IF. As of April 2026, over 120 IF
members require the filing of CbC reports and almost 90 are in a position to receive CbC reports on foreign-
headed MNE Groups through the automatic exchange of information. This means that substantially all
large MNE Groups are covered by a CbC reporting filing obligation and these reports are available to the
majority of jurisdictions that are currently in the process of implementing the GMT.
. Limitations and challenges in using CbC reports
30. While CbC reports offer a number of benefits as a source of data for estimating the population of
MNE Groups in scope of the GMT, they are also subject to a number of limitations and challenges,
described below. The extent to which these limitations and challenges are relevant in a particular case will
vary depending upon the jurisdiction relying upon the data and the profile of potential in-scope MNE Groups
in that jurisdiction.
The appropriate use of CbC reports
31. Under BEPS Action 13, CbC reports may only be used for the purposes of a high-level transfer
pricing risk assessment, for the assessment of other BEPS-related risks, and for economic and statistical
analysis, where appropriate. This does not restrict the ability of a tax administration to use CbC reports to
undertake an economic analysis to estimate the likely in-scope population of in-scope MNE Groups in its
jurisdiction, nor to undertake an initial risk assessment as to whether a particular MNE Group is likely to
be in-scope for a specific period. However, a tax administration should not use CbC reporting data as
conclusive evidence that an MNE Group or Constituent Entity is in-scope of the GMT, to require the filing
of a GIR or the payment of top-up taxes, or to impose penalties in the event of non-filing or non-payment.
Future work on a risk assessment framework for the GMT will consider steps that may be taken by a tax
administration to determine whether a particular MNE Group should have filed a GIR in circumstances
where no GIR was filed.
Differences in non-EUR denominated thresholds due to exchange rate movements
32. While Action 13 and Pillar 2 establish a common threshold of EUR 750 million, the two standards
differ in the way in which non-EUR denominated thresholds are set by jurisdictions that wish to apply a
threshold denominated in their local or other relevant currency. Specifically, under Action 13 a non-EUR
denominated threshold must be equivalent to EUR 750 million as at January 2015. On the other hand,
under Pillar 2, a non-EUR threshold must be re-based each year based on the exchange rate in December
of the relevant
17
Paragraph 19 of the Commentary to the Model Rules provides that, for the purposes of applying the thresholds for
GIR filing, jurisdictions should rebase their non-Euro denominated thresholds annually, based on the average foreign
exchange rate for the month of December determined by the foreign exchange reference rates as quoted by the
European Central Bank (ECB). Where this is not possible the jurisdiction should rebase their non-Euro denominated
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33. In practice, this means that the CbC reporting threshold and the GMT threshold are likely to differ
wherever the UPE of an MNE Group is resident in a jurisdiction that applies non-EUR denominated
thresholds, and the extent of this difference may change from year to year depending upon current
exchange rates. As such, there may be cases where a currency has depreciated against the euro meaning
that some MNE Groups are required to file a CbC report that may not be subject to the GMT, or conversely
a currency has appreciated against the euro meaning that some MNE Groups that are not required to file
CbC reports may still be subject to the GMT.
34. A jurisdiction that is using CbC reports as a source of data can estimate how much of an issue this
is likely to be by:
• identifying the jurisdictions in which the greatest number of CbC reports they receive (or used to
receive) are filed, including their own jurisdiction), and
• where these jurisdictions apply a non-EUR denominated CbC reporting threshold, considering how
much the currency of that threshold has moved against the euro since January 2015.
35. Where a jurisdiction has access to CbC reports, this difference in the applicable non-EUR
denominated thresholds for CbC reporting and the GMT is probably the biggest single limitation on the use
of this CbC reporting data for the purposes of estimating a population.
The impact of Excluded Entities
36. Article of the Model Rules identifies a number of Excluded Entities that will not be subject to
the GMT. However, the fact that a Constituent Entity is an Excluded Entity does not prevent other members
of their MNE Group from being subject to the GMT, unless they also meet the definition of an Excluded
Entity. BEPS Action 13 on the other hand does not provide for special treatment of Excluded Entities and
has no equivalent provisions for the purposes of CbC reporting. This means that a Constituent Entity that
is an Excluded Entity for the GMT will still be included in a CbC report, even where the Excluded Entity is
outside the charge to taxation under the GloBE rules.
37. The presence of an Excluded Entity in an MNE Group should not impact the usefulness of CbC
reports for the purposes of estimating the population of in-scope MNE Groups in a jurisdiction, unless the
only Constituent Entity in a particular jurisdiction is an Excluded Entity. However, the fact that a CbC report
does not include any indication that the UPE or a Constituent Entity is an Excluded Entity may lead a tax
administration to draw a conclusion that a taxpayer in its jurisdiction may be subject to the GMT when this
is not the case. To address this, additional information to identify possible Excluded Entities may be
needed. In practice, the likely number of Excluded Entities in most jurisdictions means that, even if a tax
administration does not manage to anticipate all of them, this is unlikely to significantly impact the number
of Constituent Entities expected to be subject to the GMT in a jurisdiction. Therefore, it is advisable that it
may be more efficient and effective for a tax administration to wait until after the relevant filing and
exchange deadlines, and undertake a risk assessment at that time to detect possible non-compliance, if
needed.
Partially Owned Parent Entities (POPEs), Minority Owned Constituent Entities (MOCEs)
and Joint Ventures
38. Pillar 2 also includes specific rules on other particular types of entity that are not wholly-owned
subsidiaries, namely:
• Partially Owned Parent Entities (POPEs),
thresholds based on the average foreign exchange rate for the month of December as quoted by the jurisdiction’s
Central Bank.
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• Minority Owned Constituent Entities (MOCEs), and
• Joint Ventures.
39. POPES and MOCES are controlled by the UPE of the MNE Group and so will be included in a
CbC report prepared in accordance with Action 13. However, as the CbC report does not include an MNE
Group’s group structure nor any information on cases where third parties hold ownership interests in a
Constituent Entity, it will not be possible to identify a POPE or MOCE based solely on the contents of a
CbC report.
40. This fact does not reduce the usefulness of CbC reports in estimating the population of MNE
Groups in scope of the GMT in a jurisdiction, but it does mean that additional information is needed in
order to determine whether the special rules applicable to POPEs and MOCEs apply. However, for the
purposes of estimating the in-scope population, this determination is not necessary. Therefore, it is
advisable that a tax administration wait until the GIR is received in order to undertake a risk assessment
on the correct application of these rules, if needed.
41. Joint Ventures are jointly owned entities that are not controlled by the UPE of an MNE Group and
as such are not consolidated in the MNE Group’s consolidated financial statements nor included in its CbC
report. Therefore, CbC reports will not support a tax administration in identifying Joint Ventures that are in
scope of the GMT. Other sources of data that may be used for this purpose are considered below in
Section .
The impact of duplicate CbC reports
42. When CbC reporting was first introduced for fiscal years beginning on or after 1 January 2016, a
number of jurisdictions introduced provisions to allow Constituent Entities that were not the UPE of their
MNE Group (“surrogate parent entities” or SPEs) to file a CbC report on a voluntary basis. These CbC
reports were exchanged with tax administrations in other jurisdictions where the MNE Group had
Constituent Entities. Where the UPE of an MNE Group was resident in a jurisdiction that had not introduced
a CbC reporting filing requirement or had not entered into agreements for the exchange of CbC reports,
this SPE filing helped the MNE Group to avoid being required to file a CbC report under “local filing” rules
in potentially multiple jurisdictions.
43. As more jurisdictions have introduced filing requirements and exchange agreements, the need for
SPE filing has reduced significantly, but some MNE Groups have continued to file CbC reports in two or
more jurisdictions, each of which are exchanged with tax administrations in other jurisdictions. This means
that there are cases where a tax administration receives multiple versions of an MNE Group’s CbC report
from different filing jurisdictions. There have also been cases where an MNE Group has filed an updated
CbC report for a fiscal year (. correcting errors contained in its original CbC report) but this is not
identified as an update to an existing report when it is filed and/or exchanged. Again, this could result in a
tax administration receiving two versions of an MNE Group’s CbC report, this time containing different
information. In each case the fact that more than one CbC report is being received on the same MNE
Group which could inflate the results of a process to identify MNE Groups in scope of the GMT. This issue
could be addressed if a tax administration matches CbC reports with local Constituent Entities and ensures
that any duplicate CbC reports are disregarded for the purposes of an estimate.
The de minimis threshold
44. Pillar 2 incorporates a de minimis threshold whereby an MNE Group’s Constituent Entities in a
jurisdiction are not subject to the GMT where the MNE Group has both:
• an average GloBE Revenue for the jurisdiction that is less than EUR 10 million, and
• an average GloBE Income or loss for the jurisdiction that is either a loss or less than EUR 1 million,
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computed on a three-year average basis.
45. BEPS Action 13 does not include any de minimis threshold and specifically provides that
Constituent Entities cannot be excluded from a CbC report on grounds of size or materiality. Therefore, all
jurisdictions where an MNE Group has Constituent Entities will be included in its CbC report irrespective
of the level of revenues or profits. That said, a CbC report does include information on an MNE Group’s
Revenues and Profit (Loss) before Income Tax calculated on a jurisdictional basis. Therefore, while a CbC
report is not sufficient to determine whether an MNE Group does qualify for the de minimis threshold in a
particular jurisdiction for a period, it may contain enough information to indicate whether an MNE Group
might qualify or if it is unlikely to do so.
Taxpayer Identification Numbers
46. Under BEPS Action 13, a CbC report should include the Taxpayer Identification Number (TIN) for
every Constituent Entity that has a TIN issued to it in its residence jurisdiction or, in the case of a PE the
jurisdiction where it is located. This is important to allow a tax administration to reliably match a CbC report
to the specific Constituent Entities that operate in its jurisdiction. However, in practice this is an area where
tax administrations have raised serious concerns that MNE Groups are not including TINs for some or all
Constituent Entities or are including incorrect TINs.
47. Missing or incorrect TINs should not prevent a tax administration from using CbC reports to identify
the population of MNE Groups in scope of the GMT in its jurisdiction, but they can cause a challenge in
using these reports to identify specific Constituent Entities that may be subject to the GMT. The extent of
this challenge appears to vary from jurisdiction to jurisdiction, with some tax administrations able to match
CbC reports to taxpayers in the jurisdiction more easily while others find this more difficult.
Access to CbC reports
48. As mentioned above, the majority of IF members have access to CbC reports on foreign-headed
MNE Groups, receiving these CbC reports under automatic exchange of information. However, a
significant minority of IF members, including many low-income and middle-income jurisdictions, do not
currently have access to this data.
49. Ensuring the availability of CbC reports for all IF members who consider access a priority was
identified as a key issue at the IF Plenary meeting held in Cape Town in April 2025 and work is currently
under way to support members in achieving access to CbC reports in accordance with the timeframe set
by each member. Where a jurisdiction does not currently have access to CbC reports, alternative sources
of data that could be used for the purposes of estimating the population of MNE Groups in scope of the
GMT in a jurisdiction are considered in Section and Section of this Toolkit.
. Making a broad estimate of the number of in-scope MNE Groups in a jurisdiction
50. Where a tax administration has decided to use CbC reports for the purposes of estimating the
population of MNE Groups in scope of the GMT, there are several ways in which this can be done.
51. The most straight-forward approach is simply to take the population of MNE Groups that filed a
CbC report for a recent fiscal year and assume that this will broadly correspond with population that will be
in scope of the GMT. In choosing a recent fiscal year to consider, it is important that this should not be so
recent that the filing and exchange of CbC reports for the year is not yet complete (including allowing some
time for late filings and exchanges) but not be so long ago that material changes to the in-scope population
would be expected. When relying on data from a recent fiscal year it needs to be borne in mind that MNE
Groups headquartered in many jurisdictions may have fiscal years that begin on any calendar date and
that these fiscal years typically have a length of 12 months. Furthermore, while the jurisdiction of the tax
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administration undertaking an estimate may have an earlier filing deadline, in many jurisdictions a CbC
report is only required to be filed 12 months following the end of the fiscal year (the latest filing deadline
permitted under Action 13) and CbC reports are exchanged 15 months following the end of the fiscal year
(the latest exchange deadline permitted under the CbC reporting multilateral competent authority
agreement). Based on these assumptions, if a tax administration in undertaking the exercise to estimate
the in-scope population of MNE Groups in early-2026, then:
• the filing of CbC reports for fiscal years commencing in 2025 will not yet have started,
• the filing and exchange of CbC reports for fiscal years commencing in 2024 will have started but
will not yet be complete,
• the filing and exchange of CbC reports for fiscal years commencing in 2023 should be complete
but there may still be a number of filings and/or exchanges outstanding, and
• the filing and exchange of CbC reports for fiscal years commencing in 2022 and earlier years
should now be complete.
52. In this example, a tax administration could choose to base its estimate on CbC reports for fiscal
years commencing in 2023, but feedback from tax administrations suggests that using CbC reports for
fiscal years commencing in 2022 may give a more complete picture. Ultimately, it is a decision to be taken
by a tax administration whether to rely upon data from an earlier year which may be more complete, or
data from a more recent year which may be more up to date.
53. An MNE Group is in scope of the GMT if it has consolidated group revenues above the threshold
in two out of the last four fiscal years preceding the reporting fiscal year. As such, basing an estimate of
an in-scope population on only a single year of CbC reporting data is unlikely to be entirely accurate.
Despite this, if a tax administration only requires a broad estimate of the likely in-scope population for its
current purposes (. if the first fiscal year in which the GMT will apply in the jurisdiction is still in the future
and so the in-scope population may in any case change before rules begin to apply) then this simple
approach may be sufficient for the tax administration’s needs.
. Making a more accurate estimate of the population of in-scope MNE Groups in a
jurisdiction for a particular year
54. An important difference in the way in which the revenue thresholds under BEPS Action 13 and
Pillar 2 differ is that an MNE Group is in scope of CbC reporting if it has consolidated group revenues that
meet the threshold in the immediately previous fiscal year whereas an MNE Group is in scope of the GMT
if it meets the threshold in two out of the four previous fiscal years. This smooths the effect of revenue
volatility when determining if an MNE Group is in scope of the GMT. Despite this difference, if a tax
administration needs a more accurate estimate of the population of MNE Groups in scope of the GMT for
a particular year than that described in the previous section, it may still be possible to use CbC reports to
achieve this.
55. For example, if a tax administration is undertaking an exercise in early 2026 to estimate the likely
in-scope population for the GMT for fiscal years beginning in 2024, it could undertake the following steps.
• The tax administration should identify the population of MNE Groups filing a CbC report for fiscal
years beginning in 2021, 2022 and 2023. This should provide a good indicator of the MNE Groups
that had consolidated group revenues above the threshold in their fiscal years beginning in 2020,
2021 and 2022 (because the CbC reporting threshold is based on consolidated group revenues in
the immediately preceding fiscal year).
• If an MNE Group filed a CbC report for two of these fiscal years (so 2021 and 2022, 2021 and 2023
or 2022 and 2023) then it is likely that the MNE Group will be in scope of the GMT for its fiscal year
commencing in 2024.
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• If an MNE Group filed a CbC report for only one of these fiscal years (so either 2021, 2022 or 2023
only), the tax administration may use another source of data such as the MNE Group’s published
consolidated financial statements to test whether the group had consolidated group revenues
above the threshold in its fiscal year beginning in 2023). This is because an MNE Group’s
consolidated financial statements for 2023 will generally be available (. on the group’s website)
before its CbC report for its fiscal year beginning in 2024 is filed and exchanged. If an MNE Group
filed a CbC report for either 2021, 2022 or 2023 and according to its published consolidated
financial statements it had consolidated group revenues above the threshold in 2023, then it is
likely that the MNE Group will be in scope of the GMT for its fiscal year commencing in 2024.
• For completeness, where an MNE Group filed a CbC report for either 2021 or 2022, but not for
2023, the tax administration may still consider consulting the MNE Group’s consolidated financial
statements for its fiscal year commencing in 2022 to see whether it had consolidated group
revenues above the threshold. This is because, while the deadline for filing and exchanging CbC
reports for fiscal years commencing in 2023 has passed, there may have been a delay meaning
that the CbC report has not yet been received by the tax administration, in particular if the fiscal
year of the MNE Group has a start date late in the calendar year.
. Commercial datasets
56. Tax administrations may rely on commercial data sources to estimate the population of MNE
Groups in scope of the GMT. Such estimates can complement analyses based on CbC reporting data or
serve as the basis for a standalone approach where CbC reporting data is not available. Commercial
databases, including Orbis (Box 1), Compustat, Factset, and similar sources, typically provide information
on ownership structures and financial accounts that can be used to approximate the in-scope population.
Commercial databases also usually include other potentially relevant information. Data on the sector
classifications of groups may also facilitate the exclusion of certain excluded groups, such as international
organisations. In some cases, these datasets also include TINs, which facilitate matching Corporate
Income Tax (CIT) returns or financial statements.
57. Commercial datasets have a number of limitations which need to be borne in mind when estimating
in-scope populations. First, the precision of the assessment may be limited by missing or outdated financial
information and ownership links in commercial datasets. Second, there may be differences in ownership
concepts between the GloBE Rules and the commercial dataset used. Specifically, the GloBE Rules
definition of UPE refers to control while the commercial datasets may refer purely to ownership. Third,
while commercial datasets can include information on the legal form of companies, which may be used to
identify PEs or excluded entities, coverage of such variables is often imperfect.
Box 1. Illustration of a possible commercial dataset
The Orbis dataset is an example of a commercial dataset used by the OECD and the World Bank
in bilateral engagements with countries concerning the GMT. It is a commercial dataset
commercialised by Moody’s Analytics – Bureau Van Dijk, containing information on over 620 million
companies worldwide, using approximately 170 different sources of data.
Orbis may be used to identify group structure and estimate revenue of companies covered. The
Orbis dataset contains extensive information on ownership links between Global Ultimate Owners
(GUO) and their subsidiaries as well as financial statement information, both at the consolidated and
unconsolidated level. The information on entity ownership may be used to identify likely UPEs, using
the GUO concept, and their subsidiaries.
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Orbis coverage is imperfect, especially at the subsidiary level (unconsolidated accounts), but
also in terms of ownership links. Financial information is especially well covered at the consolidated
level while unconsolidated data is less reliable. Coverage also depends on jurisdictions, with European
subsidiaries being on average somewhat better covered than subsidiaries located in other regions.
Nonetheless, a comparison of the number of in-scope MNE Groups with counts of groups filing CbC
reports for a number of jurisdictions across multiple regions suggests that the coverage of ownership
links is relatively good globally. Orbis may therefore be supplemented with information from other
sources, such as administrative data, to increase reliability.
The UPE concept from the GloBE Rules can be proxied by the GUO in Orbis. However, these
concepts may differ since the GUO concept only refers to a share of ownership rather than to control
as in the UPE definition. Under the GloBE Rules, a UPE is defined as an entity which (i) owns directly
or indirectly a Controlling Interest in any other entity; and (ii) is not owned, with a Controlling Interest,
directly or indirectly by another Similarly, Constituent Entities can be approximated by
subsidiaries. However, specific types of entities such as PEs or investment funds may not be easily
identified using Orbis data. Information on entities’ legal form can be used for this purpose, . a PE
may typically be classified as a branch or a foreign company, but with large variation in coverage across
jurisdictions.
Orbis data may be accessed in three ways: via the online Orbis platform, the historical Orbis disks
(or related solutions), and through the Wharton Research Data Services (WRDS) from the Wharton
School at the University of Pennsylvania (Kalemlİ-Özcan et al., 2024[1]). Each access mode involves
different cost considerations, coverage and operational trade-offs. While the historical Orbis access
provides the most complete access to data, it is more common that tax administrations will have online
access via the website. Online access allows to consult and download current and historical financial
data, as well as latest available ownership links. Because the online data is updated frequently, it
provides the most up-to-date picture of groups’ structures. However, this approach to data access may
limit the reproducibility of analyses. On the other hand, historical disks (“flat files”) provide information
as observed at the end of each year of observation. The timeliness of the disks is, however, limited,
and the data usually suffers a one- or two-year lag. Data obtained through the WRDS covers only
European companies (this subset of Orbis data is often referred to as the Amadeus dataset) and has
generally similar features as data downloaded via the online interface.
Table 1. Ownership data from Orbis is relatively complete
The table below provides an illustration of the data that may be available on Orbis for a sample of countries.
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Note: Column 1 shows the total number of entities recorded in Orbis for each country. Column 2 indicates the total number of entities
identified as headquarters (. GUO) of a multinational group in each country. Column 3 indicates how many of these groups were found to
be likely in scope of the GMT. Column 4 shows the number of subsidiaries of (domestic and foreign) multinational groups in each country.
Columns 5 and 6 display the number of subsidiaries that are part of MNE Groups with revenue above EUR 500 million or EUR 750 million,
respectively. Column 7 shows the number of subsidiaries that belong to an MNE Group likely to be in scope of the GMT. Column 8 shows
the count of multinational groups likely to be in scope of the GMT in each country. Columns 9 and 10 indicate the number of subsidiaries
and groups from CbC reports, for reference.
Source: Bachas et al. (2025[2])A Controlling Interest is an Ownership Interest in an Entity such that the interest holder: (a) is required to
consolidate the assets… of the Entity on a line-by-line basis in accordance with an Acceptable Financial Accounting Standard; or (b) would
have been required to consolidate (...) if the interest holder had prepared Consolidated Financial Statements.
58. In principle, several approaches can be taken to estimating the in-scope population using
commercial databases. One approach18 involves three distinct steps:
i. Identifying MNE Groups likely to be in scope of the GMT at the global level,
ii. Identifying subsidiaries of likely MNE Groups operating in a given jurisdiction, and
iii. Merging these datasets to produce the final list of in-scope subsidiaries in this jurisdiction.
The following subsections describe these steps in sequence.
Box 2. Ex f T d’ c c c
As part of its decision-making process, Thailand required that a local GMT impact assessment be
released. To inform the legislative process, the Revenue Department of Thailand estimated the in-
scope population and led an impact assessment.
The Revenue Department first received exchanged CbCR data in 2023, covering fiscal year 2021 and
involving exchanges with only 40 jurisdictions. Therefore, the estimation of in-scope MNE groups was
primarily based on Orbis. Financial information was also sourced from Orbis. Since not all Thai MNEs
are required to prepare consolidated financial statements, and given unconsolidated financial data is
not as well covered in developing countries Orbis, the tax administration noted that some in-scope
entities may not captured by this process.
A second component of the analysis undertaken by the tax administration focused on tax incentives.
After having estimated the potential additional revenue from the implementation of the GMT, the
Revenue Department analysed the main tax incentives available in Thailand to better understand the
drivers of the observed undertaxed profits. To this end, Orbis data were merged with CIT returns for
entities reporting low effective tax rates. For Thailand, the availability of TINs in Orbis facilitated the
match with tax return data. This approach allowed the Revenue Department to understand to which
extent low effective tax rates were attributable to taxpayers benefitting from tax incentives such as tax
holidays.
The impact assessment concluded that implementing the GMT would result in significant revenue gains
for Thailand. Following this assessment and a consultation process, Thailand has enacted the GloBE
Rules legislation as of January 2025.
External expertise was brought under the auspices of the Asian Development Bank to assist with
aspects of the data analysis. The OECD also provided guidance and support for the impact assessment
as part of the Pilot programmes on GMT implementation.
18
This is the approach taken by the OECD and the World Bank working in collaboration with several jurisdictions to
estimate the in-scope population as part of an economic impact assessment of the GMT using the Orbis database.
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. Create list of entities in scope globally
59. An appropriate first step in the use of a commercial data set is to identify all entities with revenue
above the GMT threshold. To this end, a subset of the commercial dataset should be constructed including
all entities (UPEs and subsidiaries) that report revenue exceeding EUR 750 million in at least one of the
years under review. As a practical approach, jurisdictions may first filter entities with consolidated financial
statements and subsequently apply the group revenue threshold. This sequencing helps narrow the
population and prioritise entities that are either UPEs or relatively high in the ownership chain. This ensures
that if financial information is missing for an ultimate parent but one of its identified subsidiary exceeds the
revenue threshold, then the entire group is also included in the in-scope population.
60. Further steps may be taken to refine the list once a dataset composed of all groups with revenue
above EUR 750 million has been constituted. In particular, the GloBE scoping rule requiring that group
revenue exceeds the threshold in at least two of the previous four fiscal years can be At this
stage, a number of common data cleaning procedures and checks may also be applied, such as removing
duplicates, harmonising data formats, or identifying and addressing outliers.
. Create list of subsidiaries operating in a jurisdiction
61. As an initial step, all entities operating in the jurisdiction under review can be identified. Practically,
this could be done using the location variable in the dataset to select the relevant jurisdiction. To limit the
scope of the query, the search should then be restricted to entities that are subsidiaries of MNE Groups.
At this stage, subsidiaries of both in-scope and out-of-scope MNE Groups should be retained. The resulting
dataset should include ownership information, notably the name and identification number of each
subsidiary and its UPE. The dataset may also contain PEs, but the coverage of such entities is typically
limited, even in jurisdictions that are otherwise well represented in commercial databases, and additional
data may therefore be required.
. Create list of in-scope subsidiaries in a jurisdiction
62. To derive the list of in-scope subsidiaries operating in a given jurisdiction, the datasets produced
in the two previous subsections should be merged. This step can be performed using statistical software.
In practice, this involves combining the list of in-scope MNE Groups at the global level with the list of
entities operating in the jurisdiction and retaining only matched records based on ownership information.
For example, if using Orbis data, this match can be conducted using the identification number (BvD ID) of
the GUO.
63. The resulting dataset should include domestic subsidiaries of MNEs that meet the revenue
threshold. This list may be linked with other data sources available to the tax administration, such as CIT
returns, financial statements, or CbCR data. Where available, TINs contained in commercial datasets can
facilitate matching with administrative records. In their absence, matching may be performed using
company names, subject to appropriate validation checks.
64. The de minimis exclusion may also be incorporated into the analysis. Under this rule, an MNE
Group’s subsidiaries in a jurisdiction are excluded from the top-up tax calculation where the group has
limited operations in that jurisdiction, defined as jurisdictions where the MNE has (i) an average GloBE
revenue that is less than €10m, and (ii) an average GloBE Income or loss that is either a loss or less than
€1m, computed on a three-year average basis. These exclusions apply on a jurisdictional basis, . to the
MNE Groupsʹ total GloBE revenue and GloBE Income in the jurisdiction. If both conditions are satisfied,
the subsidiary should be excluded from the dataset. However, as this information would require
19
This can be done using a statistical software.
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unconsolidated information, which is generally less well covered, this step would likely involve merging the
subsidiary list with either financial statements or tax returns if these are available.
. Other sources of data to estimate in-scope population
65. If a tax administration does not have access to CbC reports nor to reliable commercial data, the
following alternative sources of data may also be used to estimate the population of MNE Groups in scope
of the GMT.
• Aggregated CbC reporting data published by the OECD.
• Data or intelligence held by the tax administration.
• Consolidated financial statements.
• Pre-filing registration data.
66. These sources of data may also be used to supplement the results of an analysis using CbC
reports or commercial data. However, when using multiple sources, it is important to be aware of the risk
of duplicative results, overestimating the in-scope population. As such, it will be important to take steps to
identify and address this duplication or, as a minimum, recognise its potential impact. Jurisdictions facing
these challenges may wish to reach out to the OECD or to other partner organisations providing technical
assistance on minimum tax (see Box 4).
. Aggregated CbC reporting data published by the OECD
67. Under BEPS Action 11, each year the OECD collects from IF members anonymised and
aggregated data extracted from CbC reports filed by MNE Groups in each jurisdiction. This data is released
as part of the annual Corporate Tax Statistics publication, allowing stakeholders that do not have access
to CbC reports to undertake analyses. The latest version of this data, released in July 2025 includes data
based on CbC reports filed for fiscal years commencing in 2021 and is available to all tax administrations
including those that have not implemented Action 13.
68. In order to conduct a search of the aggregated CbC reporting data, a tax administration should:
• open the OECD Data Explorer at this link,
• select the table of data entitled Country-by-country reporting (CbCR) - Aggregate totals by
jurisdiction – Corporate Tax Statistics,
• under the heading Refine your data selection, it should:
• click on Time Period to select the latest year of data available,
• click on Reference Area and select Deselect All,
• click on Counterpart Area and select the name of its own jurisdiction (ensuring no other jurisdictions
are selected), and
• click on
20
FAQs regarding the OECD data explorer, as well as an instructional video, can be found at this link.
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Figure 1. Applying filters to aggregated CbC reporting data in the OECD Data Explorer
69. Once this search is completed, a table will be presented including aggregated data provided by IF
members on CbC reports filed by UPEs resident in their jurisdiction that contain one or more Constituent
Entities in the jurisdiction of the tax administration undertaking the search. The first two columns of this
table will include the Reference Area (. the name of the jurisdiction in which the CbC report was filed)
and the number of MNE Groups that filed a CbC report which included Constituent Entities in the
jurisdiction of the tax administration. While many IF members that provide aggregated CbC reporting data
include information on the location of Constituent Entities, this is not always the case. Some members
provide data aggregated by continent rather than by jurisdiction or only provide this data for a limited
number of jurisdictions. Information on the level of detail provided by each IF member can be found in table
of Corporate Tax Statistics The tax administration undertaking the search can aggregate the
numbers in this column to determine a broad estimate of the total number of MNE Groups headquartered
in jurisdictions that provided this level of data that may be in scope of the GMT in its jurisdiction (noting
that this is based on historic data that is several years old). This analysis also allows the tax administration
to see how many of these MNE Groups are likely to have UPEs resident in each IF member where CbC
reporting is required and that contributed to the data.
21
OECD (2025), Corporate Tax Statistics 2025, OECD Publishing, Paris,
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Figure 2. Estimating the number of in-scope MNE groups by UPE jurisdiction using aggregated
CbC reporting data
70. This indicator of the possible number of in-scope MNEs across a number of UPE jurisdictions may
be sufficient for the purposes of the tax administration undertaking the exercise. However, if the tax
administration wishes to undertake further work to better understand which MNE Groups are likely to be in
scope of the GMT, it may compare the results of this analysis with other information it holds within the tax
administration. For example, if based on the aggregated CbC reporting data it knows that there were 10
MNE Groups with the UPE located in Jurisdiction X that filed CbC reports including local Constituent
Entities, it may be able to use its own intelligence to determine which are the 10 largest MNE Groups from
Jurisdiction X with operations in its jurisdiction.
. Data or intelligence held by the tax administration
71. Tax administrations will often hold large amounts of data on their corporate taxpayers, provided
within or alongside a taxpayer’s CIT return or gathered in the process of a tax audit, an advance pricing
arrangement or other compliance action. For example, in some jurisdictions a taxpayer will be required to
tick a box on their tax return if they are a member of a large MNE Group (as defined under local tax law).
The existence and reliability of this data will vary from jurisdiction to jurisdiction depending upon local
requirements and enforcement but could be an important and useful tool for a tax administration that does
not have access to some of the other sources described in this Module.
. Consolidated financial statements
72. Most large MNE Groups prepare annual consolidated financial statements that can be obtained
separately or as part of an annual report on the group’s business and operations. Where an MNE Group
is listed on a securities exchange the publication of such financial statements will typically be required, but
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large privately held MNE Groups also often make consolidated financial statements available publicly for
the benefit of the press, analysts, lenders and investors. These financial statements (or relevant extracts
from the financial statements) are often available via the securities exchange website, a jurisdiction’s
companies registry or chamber of commerce or, often more practically, the MNE Group’s website and can
be available within three months of the fiscal year end (or sooner), which is significantly earlier than CbC
reports.
73. In undertaking an estimate of the population of in-scope MNE Groups, a tax administration may
seek views from its audit managers and other officials as to which taxpayers are likely to be members of
MNE Groups that could be within the scope of the GMT and then use the publicly available consolidated
financial statements of these MNE Groups to confirm whether this is the case. As described above for the
purposes of using CbC reports, this can either be done using a simplified approach by looking at the
consolidated financial statements for the most recent fiscal year for which information is available, or using
a more detailed multi-year approach to test whether the MNE Group had consolidated group revenues
above the threshold in two out of the four fiscal years immediately preceding a specific period. In addition,
under International Accounting Standard 12 (IAS 12), MNE Groups that prepare consolidated financial
statements using IFRS are required to disclose that they are in scope of the GMT for a period, as well as
their current tax expense related to the GMT and other Pillar 2-specific disclosures.
Box 3. Ex f U d K gd ’ u f d -scope population
The United Kingdom is an example of a jurisdiction that has used a number of different sources of data
to estimate the number of MNE groups that will potentially be in-scope of the GMT.
• CbC reporting data was used to identify MNE groups that had consolidated group revenues
above the EUR 750 million threshold for a number of fiscal years preceding the introduction of
the GMT and so may be in-scope of the GMT for fiscal years commencing in 2024. Customer
Compliance Managers (CCMs) in HM Revenue and Customs’ (HMRC) Large Business unit
were also engaged in this exercise to ensure that any changes in an MNE group’s profile or
position that could impact whether it was likely to be subject to the GMT in practice were taken
into account.
• HMRC also relied on information held by the tax administration and the experience of
officials working with potentially in-scope MNEs, including CCMs, to identify wholly domestic
groups (. those with all Constituent Entities resident in the United Kingdom and with no foreign
PEs) that could be within scope of the GMT. This was then confirmed using consolidated group
revenue figures taken from published consolidated financial statements.
• Potential Joint Ventures that could be subject to the GMT in the United Kingdom were identified
using commercial databases to search for entities that are precisely 50% owned by an MNE
group or domestic group that is itself likely to be in-scope of the GMT.
. Data obtained from registration requirements
74. For the purposes of preparing for the first GIR filings and for GMT revenue estimation, it is
generally not necessary that a tax administration identifies every in-scope MNE Group and local constituent
entity in advance of the first GIR filing/notification deadline, but an understanding of the likely scale of the
in-scope population and the broad profile of in-scope MNE Groups is beneficial. It is expected that, for the
majority of tax administrations, the data sources mentioned previously in this section will be sufficient for
these purposes. These sources also have the additional benefit that they are pre-existing and so their use
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does not imply any additional burden on MNE Groups or on tax administrations (beyond any requisite
conditions to access the data).
75. Where a tax administration does not have access to CbC reports or reliable commercial databases,
and the other alternate sources of data mentioned in this section are not sufficient, then there is the
possibility for a jurisdiction to introduce a requirement for local Constituent Entities that are part of in-scope
MNE Groups to register with its tax administration after the end of the first fiscal year for which they will be
in scope, but in advance of the GIR filing/notification deadline. This will provide the tax administration with
useful information on the MNE Groups and Constituent Entities that will be in scope of the GMT, but this
approach does imply an additional burden on the tax administration to implement and operate a registration
process and on MNE Groups to comply with such a process. As any registration requirement relies on
action to be taken by an MNE Group, the accuracy and completeness of the data it provides also depends
upon awareness of the requirement and compliance with that requirement by MNE Groups. More
information on registration requirements is included in Module 4.
. Estimating top-up tax revenue
76. This section explains, at a high level, how jurisdictions can estimate entity-level top-up tax liabilities
under the GMT using available data The GloBE computation is based on three main elements:
GloBE income, covered taxes and the Substance-Based Income Exclusion (SBIE). Figure 4 illustrates how
these concepts interact in the top-up tax calculation. Together, these variables determine the amount of
top-up tax due in a jurisdiction. The jurisdictional Effective Tax Rate (ETR) is then calculated as the ratio
of covered taxes to GloBE income, and the applicable top-up tax percentage corresponds to the difference
between this ETR and the 15% minimum tax rate under the GMT. This top-up percentage is then applied
to jurisdictional excess profit, defined as GloBE income after deduction of the SBIE. A detailed
methodology for estimating revenues from QDMTTs, including assessing the impact the treatment of
different kinds of tax incentives is presented in a forthcoming OECD-World Bank publication (OECD-World
Bank, Forthcoming 2026[3])).
Figure 3. Calculation of top-up taxes under GloBE
22
This section does not cover policy considerations that may influence whether jurisdictions should or should not
introduce a given component of the GMT rules. These considerations are discussed further in the Minimum Tax
Implementation Handbook (Pillar Two).
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Box 4. Assistance from International Organisations on GMT revenue estimation
The OECD has provided assistance to jurisdictions seeking to undertake local GMT revenue
estimations. Revenue estimation results based on anonymised and aggregated CbC reporting data has
also been made available to all IF member jurisdictions.
Bilateral assistance can take several forms, including:
1. Providing technical advice to tax administrations, for example on the interaction between the
GMT and existing tax incentives.
2. Sharing scripts for statistical software in different programming languages to support
calculations of jurisdictional effective tax rates and top up tax liabilities.
3. Supporting tax administrations in the analysis of anonymised micro-data from tax returns or
financial statements shared by jurisdictions on a confidential basis. When data availability
permits, this may include analysis of the use of tax incentive use.
Other International Organisation have also supported jurisdictions in assessing the impacts of the GMT.
For example, the World Bank has engaged with several jurisdictions wishing to estimate the potential
revenue impacts of the GMT (Bachas et al., 2025[2]), as have the IMF. The International Institute for
Sustainable Development (IISD) has also worked with a number of jurisdictions to assess how tax
incentives may be affected by the GMT.
. Data approaches and limitations
77. The most precise approach to estimating potential revenue gains from introducing a QDMTT relies
on entity-level data on ownership, income, taxes, tangible assets and payroll. After identifying the
population of in-scope entities in a jurisdiction following steps described in previous sections, certain
adjustments may be made to the data to better align the estimation with the GloBE Rules, and it is
recommended that at least three years of data be gathered for more accurate results. While more years of
data is usually preferable, the application of the de minimis exclusion is based on a three-year average.
78. Table 2 below presents different data availability scenarios, in a simplified form. The data required
for the analysis may typically be found in a combination of financial statements, tax returns and CbC
reporting data (Scenario 1). However, the availability and completeness of these datasets may vary across
jurisdictions, and different scenarios are presented in the table ranging from extensive data availability
(Scenario 1) to limited data availability (Scenario 5).23
Table 2. Key data scenarios and recommended data sources
SCENARIO 1 SCENARIO 2 SCENARIO 3 SCENARIO 4 SCENARIO 5
Available datasets
Financial
statements
Yes(2) Yes(2) No Yes(4) No
Tax returns Yes Yes Yes No Yes
CbCR Yes No Yes No No
23
In the absence of any tax return, financial statement or CbC reporting data, jurisdictions may consider jurisdiction-
specific QDMTT estimates based on publicly available and aggregated data, which are available on request from the
OECD. These estimates have been shared with officials of Inclusive Framework members on a bilateral basis. It is
important to note that these include important caveats as they rely on aggregated data.
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Variable sources
Scope
CbCR
Commercial data
or imputations
CbCR
Commercial data
or imputations
Commercial data
or imputations
Income(1) Financial
statements (profit
before taxes or
FANIL)
Financial
statements (profit
before taxes or
FANIL)
CbCR (profit
before income
tax)
Financial
statements (profit
before taxes or
FANIL)
Tax returns
(accounting profit
or taxable income)
Covered
Taxes
Tax returns Tax returns Tax returns
Financial
statements
Tax returns
Payroll Financial
statements
Financial
statements
Imputations(3)
Financial
statements
Imputations(5)
Tangible
Assets
Financial
statements or
CbCR
Financial
statements
CbCR
Financial
statements
Imputations(5)
Notes:
(1) Adjustment for Qualified Refundable Tax Credits (QRTCs) or non-refundable tax credits also involves variables from tax return.
(2) Includes the scenario where financial statement items are reported in the tax return.
(3) Imputation using CbCR information on number of employees multiplied by average wages from other sources (. survey).
(4) Financial statements referred to here may be obtainable from a commercial registry in which firms may be obliged to report. A commercial
database (such as Compustat or Orbis) might be another source of financial statement data, although the coverage of such databases varies
considerably between jurisdictions.
(5) Imputation using other data sources on payroll and tangible assets (. business statistics).
Source: Based on forthcoming OECD-World Bank paper (Forthcoming 2026[3])
79. CbC reporting data provides the best starting point for identifying in-scope entities (see Section
) and contains useful information for the construction of GloBE variables. Since CbC reports contain
information on the global allocation of income, profit, taxes paid and economic substance, they may be
used to approximate GloBE income, Covered Taxes, tangible assets and payroll (see Section for a
discussion on the appropriate use of CbCR data). However, this data may not be available to all
jurisdictions as discussed above.
80. Financial accounts at the entity level provide the preferred starting point for the estimation of
undertaxed profits, especially when they can be linked with tax return data. The GloBE Rules define the
calculation of each Constituent Entity’s ETR based on the income and tax amounts from financial
statements. The starting point for GloBE Income is, for example, the financial accounting net income or
loss (FANIL), with some appropriate adjustments. Where financial accounts can be linked with tax return
data, additional adjustments may be made to Covered Taxes, such as use of qualifying tax incentives,
qualifying refundable tax credits and of deferred tax assets, such as loss carry-forwards.
81. Where financial accounts data is not readily available to the tax administration, the revenue
estimation may rely upon other data sources. If financial accounting data is not collected for tax purposes,
jurisdictions should assess whether it can be obtained from other government bodies and matched with
administrative tax data. Tax administrations may also consider commercial providers like Orbis, noting that
data quality and ownership coverage vary by country. Where neither source is feasible, GloBE concepts
may be approximated using administrative tax data, subject to important limitations.
82. Imputation of information should be used only as a last resort when data for a variable or
observation is missing. It involves replacing missing or inconsistent values with reasonable substitutes to
preserve dataset usability. Common approaches include using overall averages or medians, or, where
values differ across groups (. sectors), subgroup averages or medians. Where sufficient data is
available, more advanced methods such as regression-based imputation may also be applied.
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. Main adjustments for the estimation of top-up tax revenue
83. This section provides an overview of the main concepts and adjustments required for the
estimation of QDMTT revenue in a given jurisdiction. More details can be found in a forthcoming OECD-
World Bank guide to QDMTT estimation (OECD-World Bank, Forthcoming 2026[3]). Potential revenue from
the IIR and the UTPR are not discussed here, though many of the data sources here may also be relevant
for estimation of IIR revenue estimation.
Jurisdictional blending
84. Under the jurisdictional blending rule, the GloBE Income, Covered Taxes and SBIE of all
subsidiaries of the same MNE Group within a jurisdiction must be aggregated when performing estimates.
This requires group structure information to identify and combine the relevant entities. Where such
information is unavailable, calculations may be undertaken at the individual entity level as an
approximation, but this approach is likely to overestimate revenue. This is because under the blending
rules that are part of the GMT calculation, low-taxed profit in one entity can be offset by higher-taxed profit
in another entity. If this is not taken into account by undertaking calculations at the jurisdiction level,
revenues may be overstated.
GloBE Income
85. Under the rules, GloBE Income is derived from FANIL, as reported in consolidated financial
statements, subject to a series of adjustments intended to better align the measure with taxable
Some of the main adjustments are explained below.
86. A key adjustment is the addition of Covered Taxes. Covered Taxes broadly correspond to the net
tax expense and profit before tax is equal to FANIL plus net tax expense, so that profit before tax provides
a practical starting point for estimating GloBE Income using firm-level data. Jurisdictions are therefore
encouraged to rely on profit before tax, or a closely related accounting income measure, where available.
Preferred sources include profit before tax reported in financial statements or in tax returns before
jurisdiction-specific tax adjustments, while measures reported after such adjustments are less suitable
because they reflect domestic tax rules that may not align with GloBE adjustments. Taxable income is
generally a less suitable proxy, as it already incorporates exemptions and deductions that are likely to differ
from the GloBE Rules. Where profit before tax is not directly reported, it may be approximated using
reported revenue and cost items before tax adjustments.
87. A second key adjustment is the subtraction of dividend income. Since dividend income is typically
reported separately in tax returns, it is recommended that jurisdictions make this adjustment. While an
exception to the exclusion of dividend income is made for short term portfolio shareholding, it is usually
not possible to determine this specific amount, it is recommended that all dividend income be deducted.
88. Lastly, certain types of tax credits should be added to GloBE Income. Under the GloBE Rules,
refundable credits, and marketable or transferable credits, which “qualify” are included in GloBE Income.
Other tax credits are excluded and only reduce covered taxes.
Covered Taxes
89. Under the GloBE Rules, Covered Taxes are based on the current tax expense reported in a
company’s financial statements. Covered taxes are limited to taxes on corporate income, including relevant
foreign taxes such as withholding and CFC taxes, and excluding non-income taxes. While the rules rely
24
The GloBE Information Return (GIR) lists all necessary adjustments to FANIL following the GloBE Rules, including
net taxes, dividends, equity gains and losses, etc.
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on financial accounting data, jurisdictions can generally approximate Covered Taxes using the amount of
CIT accrued for the year in tax returns. In practice, tax return data often provides a workable starting point
and may be better suited for applying key adjustments where detailed financial statement breakdowns are
not available.
90. When using tax return data, jurisdictions should consider applying a limited set of priority
adjustments to improve alignment with the GloBE framew
