OECD updates Pillar Two filing guidance as KPMG warns of deadline pressure

The OECD gave Pillar Two teams a useful breather on May 18, but not a clean escape hatch. Its new materials were aimed at central filing of the GloBE Information Return, yet the caveats meant multinational tax teams still had to work through local portal readiness, exchange links and fallback filing rules before the first big deadline hit on June 30, 2026.

KPMG’s EU Tax Centre said the package covered three pieces: guidance on central filing and exchange of the GloBE Information Return, updates to the Central Record, and administrative guidance on the transitional UTPR safe harbour for multinational groups with 52-53 week fiscal years. For calendar-year groups with 31 December 2024 year-ends, the filing season is now here, and the OECD said the common understanding was meant to reduce delays where filing portals or exchange relationships are not fully in place.

That is the false comfort. KPMG said 33 of the 38 jurisdictions implementing the global minimum tax for 2024 signed on to the common understanding, but several practical blockers remain. Some jurisdictions have been slow to activate bilateral exchange relationships, some have not transposed DAC9, and some still do not have local filing portals. The OECD’s approach can reduce the local filing burden by allowing one central GIR submission to be exchanged with other jurisdictions, but the relief is only as good as the links between authorities. KPMG also noted that the OECD refers to 37 jurisdictions in one count because Cyprus has implemented the GMT for 2024 but is not a member of the Inclusive Framework.

The United Kingdom moved quickly. HM Revenue & Customs said it opened its GIR portal on May 19, 2026, and backed the OECD transitional approach where the GIR filing deadline is no later than December 31, 2026. Under the UK approach, if a GIR is centrally filed in one of the listed jurisdictions and the information is received within six months of the filing deadline, HMRC will not enforce local filing and will reduce certain penalties to nil, provided the overseas return notification is filed on time. But if the centrally filed GIR is not received within six months, HMRC said it may enforce local filing and start charging late-filing penalties.

The Central Record update also sharpened the map for minimum-tax work. KPMG and EY said the OECD added the Bahamas, Kenya, Kuwait and Oman as jurisdictions with qualified domestic minimum top-up tax rules and QDMTT safe harbours, bringing the total to 50 listed jurisdictions. EY also said the OECD clarified that MNE groups with a 53-week fiscal year ending on or before January 3, 2027, can qualify for the transitional UTPR safe harbour. For KPMG tax teams, the message is familiar: the policy headline may read easing, but execution risk still sits in the workstreams that matter most, from data and notifications to filing mechanics and exchange timing.