GIR Filing for Pillar Two: what you still need to do before June 30

For groups within the scope of the Minimum Tax Act 2024, June 30, 2026, is the first actual Pillar Two deadline. On that date, the Tax and Customs Administration expects to receive the first supplementary tax return (GIR) for the 2024 reporting year. For many multinational groups, this is the moment when all preparations for Pillar Two come together in a single concrete filing. This is also where the bulk of the time and effort is currently being invested.

What exactly is the GIR, and who is required to file it?

The GIR (GloBE Information Return) is the standardized return form that in-scope groups use to report whether additional tax is due under Pillar Two for each jurisdiction. In the Netherlands, the return is also known as the “additional tax information return” (BIA). The obligation applies to groups that had consolidated revenue of at least €750 million in at least two of the four preceding fiscal years. Filing takes place in XML format via Digipoort. The XML schema has been available from the Dutch Tax and Customs Administration since April 23, 2026, and complies with the international standard of the OECD Inclusive Framework.

Even if no additional tax is due per jurisdiction, the filing obligation remains in effect. The GIR is an information return, not a tax return.

The Dutch timeline at a glance

For calendar-year groups with a reporting year of 2024, the first cycle is as follows:

• June 1, 2026: Digipoort opens for GIR filing and local additional tax return filing.
• June 2, 2026: The Data Portal opens for the Pillar II notification (registration that your entity is subject to the Minimum Tax Act).
• June 30, 2026: Deadline for GIR filing for calendar-year groups that were already in scope in FY2024.
• August 31, 2026: Deadline for GIR filing for groups that first fell within the scope in FY2024 (five-month extension).
• August 31, 2026: Deadline for filing the local additional tax return and making payment, only if additional tax is due in the Netherlands.

Starting with the 2025 reporting year, the deadline for the GIR will be shortened to 15 months after the end of the fiscal year, and that for the local return to 17 months.

Three mistakes we’ve been hearing about most often in recent weeks

The UPE assumption. Many Dutch subsidiaries assumed that the Ultimate Parent Entity abroad would file the GIR on behalf of the entire group, and that a Dutch filing would therefore not be necessary. This is only true if a valid information exchange treaty is in effect between the two countries (such as DAC9 within the EU or the GIR MCAA outside the EU) and if the Dutch entity submits a notification via the Data Portal. If you fail to submit that notification, you are still required to file the return yourself.

The ETR that doesn’t balance. The effective tax rate (ETR) per jurisdiction must match both your financial accounts and your CbCR data. Tax teams that compile these figures in separate spreadsheets often don’t realize until the final validation that their reconciliation between GAAP figures and GloBE adjustments doesn’t balance. Without a balanced ETR, you cannot perform the safe harbor test or submit a GIR that passes validation.

Safe harbors are overestimated. The Transitional CbCR Safe Harbor applies only to FY2024 under strict conditions (the routine profits test, the ETR test, or the de minimis test), and the threshold for the ETR test increases: 15% for FY2024, 16% for FY2025, and 17% for FY2026. Groups that thought they were “covered by the safe harbors” often find themselves, in practice, relying on a single test that falls just short of being conclusive.

What You Can Still Correct This Week

For those who are still behind schedule, the priority is no longer perfection but timely and verifiable submission. Work in this order:

1. Check the scope per entity. Which Dutch entities fall under the Minimum Tax Act? Compare this with your CbCR notification; the Tax and Customs Administration uses the same €750 million threshold there.
2. Submit the notification via the Data Portal. This is a quick registration via eHerkenning, but it is not interchangeable with the GIR itself.
3. Validate your XML against the OECD schema. The Tax and Customs Administration does not accept GIRs that do not conform to the schema. Perform this validation well in advance of June 30, not on the day itself.
4. Ensure your CbCR data and your GIR data match. For each jurisdiction, revenue and tax paid must match. Any discrepancies that you do not explain yourself now will be sent back to you later in the form of an inquiry letter.

What Comes After June 30

New deadlines will take effect immediately after the initial filing. Starting in 2027, the GIR filing deadline will be shortened to fifteen months; the UTPR (Undertaxed Profits Rule) has been in effect since FY2025; and the international exchange of information between tax authorities via DAC9 will begin on December 1, 2026. For most groups, this means that the current approach of handling projects on a case-by-case basis is no longer sustainable. A repeatable data pipeline, with consistent validation between financial accounts, CbCR, and GIR, will become the norm rather than the exception.

How SureSync Works in This Context

SureSync supports groups that want to consistently publish their financial data from multiple source systems to Digipoort and other channels. We integrate with existing systems, validate XML filings before submission, and maintain audit trails for each jurisdiction. This applies not only to the GIR but also to your CbCR data flows to the Tax Authority and the Chamber of Commerce. Would you like to discuss how to successfully complete your first GIR submission or structurally improve your approach for the next cycle? Schedule a meeting with our experts.