On June 30, 2025, the 日本の国税庁 (Nihon no Kokuzei-Cho – National Tax Agency of Japan) published a new supplementary guide on the GloBE Information Return (GIR) as part of the implementation of Pillar Two of the OECD’s BEPS project. This new framework has important implications for large multinational groups operating in Japan, particularly regarding 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 version represents a key step in the progressive adoption of the GloBE model into Japanese law and is aligned with the technical standards defined by the OECD.
Regulatory Background: Pillar Two and the Global Minimum Tax
The GloBE Information Return is a crucial component of Pillar Two of the BEPS (Base Erosion and Profit Shifting) Inclusive Framework, which introduces a 15% Global Minimum Tax for multinational groups with consolidated annual revenues of at least €750 million. This regime aims to limit tax base erosion by ensuring a minimum level of effective taxation in each jurisdiction where the group operates.
The Japanese government has been adopting gradual measures to incorporate these provisions into its domestic tax system. The GIR functions as a standardized reporting tool to facilitate assessing multinational groups’ compliance with the minimum tax burden in each country.
Technical Details of the GloBE Return
The guide published by the 国税庁 specifies that the GIR must be filed using Forms Annexes A1 and A2, which follow the data format defined by the OECD in March 2023. These annexes must report the following:
- Revenue, expenses, and adjusted profits according to the GloBE calculation.
- The effective tax rate by jurisdiction.
- Substance exclusions and other allowable deductions.
- The additional minimum tax, if applicable.
Likewise, the document emphasizes that returns must be filed in XML format, according to 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 GIR requirement in its tax legislation for the 2025 fiscal year, expecting the first reports to be filed in the 2026 calendar year. Multinational groups operating in Japan must 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 国税庁 are:
- Complete alignment with OECD technical formats, with slight local adaptations.
- The mandatory GIR filing through the 国税庁 e-Tax portal.
- The mandatory use of digital certificates and structured XML file validations before filing.
It should be noted that Japan does not currently contemplate broad exceptions to the filing obligation, except for those provided for by the OECD, such as transition periods or consolidation exclusions.
Considerations for Multinational Groups
The entry into force of the new reporting regime under Pillar Two represents a substantial change in the approach of multinational groups to their tax compliance. The obligation to report consolidated information globally—such as income, taxes, and adjustments by jurisdiction—requires efficient coordination between the tax, accounting, legal, and technology areas. 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.
Likewise, effective compliance requires a thorough evaluation of current tax structures, as any inconsistency 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 to adapt to an increasingly regulated and internationally monitored tax environment.
Conclusion
The publication of the guide on the GloBE Information Statement by the 国税庁 reinforces Japan’s commitment to implementing the OECD’s Pillar Two, demonstrating a clear signal to multinational groups: Tax transparency and global consistency in taxation are no longer optional.
To the extent these requirements become effective, taxpayers should thoroughly analyze the effects 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 also become a key factor in international corporate compliance.
Source: National Tax Agency