On June 30, 2025, the National Tax Agency (NTA) of Japan published new supplementary guidance on the GloBE Information Return (GIR) in connection with the implementation of the Second Pillar of the OECD’s BEPS project. This new framework has important implications for large multinational groups operating in Japan, particularly in relation to the Global Minimum Tax.
The official document, entitled “Overview of the GloBE Information Return (Annex A1/A2),” details the specific requirements that taxpayers must meet in the GIR filing process. The published draft represents a key step in the progressive adoption of the GloBE model into Japanese law and aligns with the technical standards defined by the OECD.
Regulatory context: Pillar Two and the Global Minimum Tax
The GloBE Information Affidavit is an essential component of Pillar Two of the inclusive framework on BEPS (Base Erosion and Profit Shifting), which introduces a Global Minimum Tax of 15% for multinational groups with consolidated annual revenues of at least €750 million. This regime seeks to limit tax base erosion by ensuring a minimum level of effective taxation in each jurisdiction where the group operates.
In the case of Japan, the government has been taking gradual steps to incorporate these provisions into its domestic tax system. The GIR serves as a standardized reporting tool, the purpose of which is to facilitate the assessment of multinational groups’ compliance with the minimum tax burden in each country.
Technical details of the GloBE return
The guidance published by the NTA specifies that the GIR must be filed using Forms Annex A1 and Annex A2, which follow the data format defined by the OECD in March 2023. These annexes require the reporting of:
- Income, expenses, and adjusted profits in accordance with the GloBE calculation.
- The effective tax rate per jurisdiction.
- Exclusions by substance and other allowable deductions.
- The additional minimum tax, if applicable.
The document also emphasizes that the returns must be filed in XML format, in accordance with the electronic information exchange standard proposed by the OECD, which requires groups to adapt their internal tax compliance and accounting systems.
Implementation in Japan: timeframe and requirements
Japan will implement the TIE reporting requirement as part of its tax legislation for the 2025 fiscal year, and the first reports are expected to be filed in the 2026 calendar year. Multinational groups with a presence in Japan will need to coordinate internally to consolidate and validate the accounting and tax information of all their operating entities in different jurisdictions.
Among the key elements mentioned by the NTA are:
- Full alignment with OECD technical formats, with slight local adaptations.
- The requirement to file the TCR through the NTA’s e-Tax portal.
- The mandatory use of digital certificates and structured XML file validations prior to filing.
It should be noted that Japan does not currently contemplate broad exceptions to the filing requirement, except as provided by the OECD with respect to transition periods or exclusions due to consolidation.
Considerations for multinational groups
The entry into force of the new reporting regime under Pillar Two represents a substantial change in the way multinational groups approach tax compliance. The obligation to report consolidated information at the global level—such as income, taxes, and adjustments by jurisdiction—requires efficient coordination between the tax, accounting, legal, and technology departments. This transformation not only requires technical adjustments to comply with the XML format, but also a thorough review of internal processes to ensure the consistency and traceability of the data submitted.
Effective compliance also requires a rigorous assessment of current tax structures, as any inconsistencies between accounting results and GloBE adjustments may result in penalties or tax adjustments. Companies should anticipate potential impacts by reviewing their transfer pricing policies, financing terms, and cross-border operations in order to adapt to an increasingly regulated and internationally monitored tax environment.
Conclusion
The publication of the NTA’s guidance on the GloBE Information Affidavit reinforces Japan’s commitment to the implementation of Pillar Two of the OECD and sends a clear signal to multinational groups: tax transparency and global consistency in taxation are no longer optional.
As the effective date of these requirements approaches, it is essential that taxpayers thoroughly analyze the impact of the new rules, adopt appropriate technological solutions, and align their tax structures with global standards. Proper filing of the GIR will not only avoid penalties but will also become a key factor in international corporate compliance.
Source: National Tax Agency