The headline items in the Inclusive Framework's 11 September 2026 release were technical: explicitly conditional taxes and the QDMTT Safe Harbour where accounting periods differ. We've written about both separately. This post covers the other two parts, which are less about calculation and more about process.
From self-assessment to peer review
Until now, whether a jurisdiction's IIR, UTPR or domestic minimum tax counted as "qualified" has largely rested on transitional qualified status, recorded centrally on the basis of the jurisdiction's own assessment. The September package publishes the terms of reference and methodology for the next step: full legislative peer reviews.
The review asks whether a jurisdiction's IIR, UTPR and QDMTT legislation is consistent with the Model Rules, the Commentary and the Administrative Guidance. On timing:
- jurisdictions whose rules took effect on or before 1 April 2025 generally have a three-year transitional window to start their review;
- jurisdictions implementing later are expected to be reviewed closer to their effective date.
An adverse outcome is expected to apply prospectively, by reference to fiscal years, rather than unwinding years already filed.
Why groups should care
Qualified status isn't a label. It decides how other jurisdictions treat a country's rules: the order in which IIR and UTPR apply, whether top-up tax is credited or duplicated, and whether the QDMTT Safe Harbour is available at all. A jurisdiction losing qualified status for its QDMTT would turn a "nil, safe harbour applies" line into a full GloBE computation for that jurisdiction. Nothing has been withdrawn yet, but reviews of early adopters will run through the next few years, and that is the same period in which most groups are settling their processes.
A revised GloBE Information Return
The package also includes an updated GIR. It reflects the January 2026 Side-by-Side package and the simplifications agreed with it, and it applies only to GIRs for fiscal years beginning on or after 31 December 2025. There is a separate allowance for applying some of the clarificatory notes on existing fields later.
The practical consequence is that, for a while, two versions of the return are live at once. Prior years, including any late or amended FY2024 and FY2025 filings, keep using the earlier template. Your first year under the new template is the year beginning on or after 31 December 2025, which for a calendar-year group is 2026. An XML schema to match the revised return is still to come, so the electronic filing side of the change can't be finalised yet.
What to plan for
- Know which template applies to which year. Tag every GIR dataset with the template version, not just the fiscal year. Mixing them up is an easy, avoidable error.
- Map the new fields against your data. Where the revised return reflects Side-by-Side or other simplifications, check whether your group uses them and what each section now needs.
- Watch the XML schema. Don't build final electronic filing logic for the new template until it is published.
- Track review outcomes for your QDMTT jurisdictions. If a key jurisdiction's review goes badly, you want to know early enough to model the full computation.
Pillar2OS keeps each GIR tied to the template version and fiscal year it was prepared under, so an amended prior-year return and a new-template return can sit side by side without overwriting each other. See the Compliance Centre.