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Taxes · PDF

January 2025 GIR Guidance: A Single Reporting Basis

Guidance on Articles 8.1.4 and 8.1.5 addresses GIR preparation where implementing jurisdictions have differences in their domestic GloBE rules.

Source checked · 11 October 2026

Coordinated information reporting

The guidance seeks a single source for each GIR section to preserve centralised filing. Where multiple jurisdictions have taxing rights, the model rules and Commentary provide the reporting basis. The document distinguishes circumstances where a single jurisdiction has the relevant taxing right and using that jurisdiction’s legislation avoids duplicate computation.

Differences and local requirements

Groups disclose impacts of differences on key indicators. Tax administrations may seek supporting information, and constitutional or administrative constraints may justify necessary, proportionate local reporting. The standard GIR does not eliminate domestic tax returns or payment duties. Read the actual amended Commentary language and the required GIR edition before deciding the reporting basis.

Official source

A concise, independent Apex Gateway guide based on the official English source, not a reproduction of the complete document. Consult the original for full conditions, exceptions and subsequent updates.

Read the official PDF ↗
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