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OECD Updates GloBE Information Return and Issues New Administrative Guidance: Implications for Multinational Groups in Indonesia

September 30, 2026

September 2026, the Organization for Economic Co-operation and Development (OECD)/G20 Inclusive Framework on BEPS (Inclusive Framework) released a new package to support the consistent implementation of Global Minimum Tax (GMT) in various jurisdictions. The package contains  a full legislative review framework for the domestic rules of implementing countries,  updates to the GloBE Information Return (GIR), and  new administrative guidance (AG). The AG regulates two things, namely the treatment of explicitly conditional taxes and the use of local accounting standards in the calculation of Qualified Domestic Minimum Top-up Tax (QDMTT). This release is relevant for constituent entities in Indonesia that are members of multinational groups with a consolidated gross turnover of at least EUR750 million.

Change Background 

The OECD’s Pillar Two sets  a minimum effective tax rate (ETR) of 15% for each jurisdiction in which the multinational group operates. If a jurisdiction’s ETR is below 15%, the difference is collected as a top-up tax) through QDMTT, the Income Inclusion Rule (IIR), or the Undertaxed Profits Rule (UTPR).

On January 5, 2026, the Inclusive Framework agreed on a side-by-side package. This package allows the GloBE Rules to run side by side with domestic regimes that are considered equivalent and introduce a number of  new safe harbours, including Side-by-Side Safe Harbour, UPE Safe Harbour, and Simplified ETR Safe Harbour, as well as extending the Transitional CbCR Safe Harbour. When the package was issued, the United States was the only jurisdiction registered as a Qualified Side-by-Side Regime. The package document also states that the GIR, XML scheme, and validation rules need to be adjusted so that  new safe harbors can be reported. The September 2026 GIR update is a follow-up to that plan. In Indonesia, GMT is regulated in Government Regulation Number 55 of 2022 (PP 55/2022) and Minister of Finance Regulation Number 136 of 2024 (PMK 136/2024). Administrative procedures, including the submission of GIR in XML format, are further regulated in the Regulation of the Director General of Taxes Number PER-6/PJ/2026.

GiR Changes

The GIR is a standard form that constituent entities fill out to report the implementation of GloBE. The OECD states that the new version of the GIR contains a simplification of the side-by-side package and only applies to the GIR for the fiscal year beginning on or after 31 December 2025. For the previous fiscal year, the group still refers to the previous version of the GIR. Despite the simplifications, the GIR still requires detailed data, ranging from the group structure and identity of the constituent entities to the allocation of GloBE income, adjusted covered taxes, calculation of ETRs, top-up taxes, and  selected safe harbours. The OECD is also preparing a new XML scheme that follows the GIR. According to the OECD, the scheme will be released soon so that tax authorities and multinational groups have time to adjust their data collection, reporting, and information exchange systems.

Explicitly conditional taxes are not recognized as covered taxes

The Side-by-side package has affirmed the principle that taxes that are conditional or discriminatory are not recognized as covered taxes. AG September 2026 applies that principle to the explicitly conditional tax category, which is a tax whose imposition depends on whether the entity is subject to an IIR or UTPR that is qualified in another jurisdiction and does not meet the Side-by-Side Safe Harbor qualifications. A contrary formulation is also covered, e.g. taxes are exempted when foreign IIRs or UTPRs are not applicable or when Side-by-Side Safe Harbour is available. According to the OECD, such taxes are detrimental to the groups covered by GloBE and benefit the excluded groups through Side-by-Side Safe Harbour. As a result, they are excluded from adjusted covered taxes and are not added back to the accounting profit when calculating GloBE’s income.

QDMTT with local accounting standards

The second part  of the guidance regulates situations when the financial statement period of the constituent entity is different from the fiscal year of the ultimate parent entity (EPU). Under certain conditions, the QDMTT must be calculated from the financial statements prepared based on local accounting standards. The OECD affirms that the Safe Harbour QDMTT can still apply in such situations, including when the required fiscal period of the QDMTT is not the same as the fiscal year of the EPU.

Implications for multinational groups in Indonesia

• Domestic adoption. The DGT has not announced the adoption of the new version of the GIR, its XML scheme, or  the safe harbour of the side-by-side package. Taxpayers should wait for regulatory changes or confirmation from the DGT.
• Calculation of ETR. Exemption of explicitly conditional taxes can lower the ETR and increase the top-up tax. For UPEs in Indonesia, top-up tax on overseas subsidiaries can be collected through IIR in Indonesia if the jurisdiction does not have a qualified QDMTT.
• Accounting period. Entities in Indonesia whose accounting period is different from the group’s consolidation period need to check the eligibility  of QDMTT Safe Harbour, while still referring to PMK 136/2024.

Conclusion

The OECD September 2026 package changes the format of the GIR for fiscal years beginning on or after 31 December 2025, confirms that explicitly conditional taxes are not recognized as covered taxes, and ensures  that the Safe Harbour QDMTT remains available when the QDMTT is calculated with local accounting standards in different periods of the UPE fiscal year. GloBE-covered multinational groups in Indonesia need to take into account their impact on ETRs, safe harbour feasibility, and reporting system readiness, while waiting for clarity on their adoption in domestic terms.

The Andersen in Indonesia team is ready to help your group assess the impact of this update, review the calculation of ETR and safe harbour, and prepare the GIR and other GloBE obligations in accordance with PMK 136/2024 and PER-6/PJ/2026. Contact us to discuss your group’s specific needs.