The deadline for filing the first GloBE Information Return (GIR) for the 2024 fiscal year of June 30, 2026, is approaching. Affected multinational groups should therefore familiarize themselves with the registration and filing process. Whether filing relief is available depends on the activation of the multilateral agreement among the competent authorities regarding the exchange of GloBE information.
The GIR for the 2024 fiscal year must be submitted in XML format via the ePortal by June 30, 2026. The Federal Tax Administration (FTA) published the guidelines for submitting the GIR at the beginning of the year and provided further details on May 11, 2026.
The GIR is a standardized information report that provides data for the entire relevant multinational group across all jurisdictions. Tax authorities can use the information in the GIR to assess whether a group has correctly calculated its GloBE tax rate and the resulting top-up taxes. The GIR serves exclusively for informational purposes and does not constitute a tax return. The actual assessment and payment of the top-up tax are carried out via the so-called qualified domestic minimum top-up tax return (QDMTT-return), which in Switzerland must be filed via the separate e-platform OMTax in the e-Portal.
If a multinational group falls under the Minimum Tax Regulation, it is generally required to file a GIR in addition to the QDMTT-return. An exemption from the GIR filing requirement applies if the GIR is filed by the Ultimate Parent Entity (UPE) or a Designated Filing Entity (DFE) in another jurisdiction that has signed the Multilateral Competent Authority Agreement on the exchange of GloBE information (MCAA-GIR). In this case, only a GIR notification is required in Switzerland. The OECD publishes a list of countries that have signed the MCAA. This list is updated regularly (Signatories of the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA).
Switzerland has signed the MCAA. Parliament approved it in March 2026. Provided no referendum is called, the agreement is scheduled to enter into force on July 10, 2026. The first international exchange of GIR data is to take place by December 31, 2026, at the latest. It is likely that some of the 37 countries that have implemented a QIIR/QDMTT will not ratify the agreement in time for an exchange in 2026.
To address these compliance and coordination challenges, the OECD published, among other things, a common understanding on May 18, 2026. Accordingly, the affected jurisdictions intend to avoid adverse consequences for taxpayers and waive penalties in this regard if the GIR has been submitted centrally to a jurisdiction in a timely manner, that jurisdiction is operationally ready for an exchange, and local notification has taken place (even if the GIR MCAA has not yet been formally activated). The annex to the mutual agreement lists the 33 countries that are expected to be able to make the central submission tool available before the end of May 2026.