GloBE – automatic exchange of information – first signatories of the multilateral agreement (GIR-MCAA) and other tools for handling GloBE.

On 6 August 2024, a list of 14 signatories to the multilateral agreement on information exchange GloBE (GIR-MCAA, GloBE Information Return-Multilateral Competent Authority Agreement) was announced. The list includes several EU Member States (Austria, Belgium, Denmark, France, Spain, Ireland, Luxembourg, Portugal, Slovakia, Italy) as well as Japan, Korea, New Zealand and the United Kingdom. By signing the GIR-MCAA, the signatories have committed themselves to automatically exchanging specific information on how multinational companies operate and what taxes they pay in those countries.

The GloBE Model Rules provide that a constituent entity of an multinational group (MNE) should, on an annual basis, submit a GloBE Information Return (GIR) to the competent tax authorities of its country of residence. However, this entity may be exempted from the obligation to submit a GIR in its country of residence, provided that the GIR – in accordance with the GloBE requirements – is submitted (within the prescribed time limit) by the parent entity or the designated entity (for the submission of the GIR) established in a country that has concluded a relevant agreement with the country of residence of the constituent entity (the so-called Qualifying Competent Authority Agreement). Importantly, the GIR-MCAA constitutes such an agreement.

Accession to the GIR MCAA is an optimal solution from the point of view of countries, as they will not be required to negotiate bilateral agreements. This solution has already been adopted by countries in the past, e.g. for the purpose of adopting a common standard for the exchange of tax information with other countries (under the CRS – Common Reporting Standard). It can therefore be assumed that Poland will soon join the group of countries that have signed the GIR-MCAA – provisions on the exchange of information included in the GIR between Poland and other countries will most likely be included in the Act on the exchange of tax information with other countries.

Link to the document: https://www.oecd.org/content/dam/oecd/en/topics/policy-sub-issues/global-minimum-tax/multilateral-competent-authority-agreement-exchange-of-globe-information.pdf

On 30 July 2025, the OECD published an XML schema for the GIR status message (GIR Status Message XML Schema). The XML schema for the GIR status message will allow competent authorities that have received GIR information (in XML format) to provide feedback to the sending authority on whether the file contained errors at the file or individual record level.

Link: OECD releases data exchange formats for the global minimum tax and crypto reporting, and issues updated FAQs

In case you are interested in the above information and its impact on your business, please contact:

or your adviser from MDDP.

This Tax Alert does not provide legal or tax advice. MDDP Michalik Dłuska Dziedzic & Partners spółka doradztwa podatkowego spółka akcyjna is not responsible for the use of the information provided in the Alert without the prior consultation with legal or tax advisers.