Perspectives · Tax
The first Pillar Two return is a list of every entity you own
The minimum tax directive was to be transposed by 31 December 2023 and applies to fiscal years beginning on or after 31 December 2023, and the first GloBE Information Return covering that year falls due on 30 June 2026 for calendar-year groups in many jurisdictions. The date is not universal: some jurisdictions set earlier registration or notification dates, some brought local minimum tax returns forward, and others have granted extensions for particular forms. Within the EU, the directive on administrative cooperation adopted on 14 April 2025 allows the return to be filed once and exchanged between authorities. What every version of the filing has in common is its opening requirement, which is a complete list of the group's entities. This perspective is general information, not legal advice.
22 June 2026 · Tax
The return
The first return is being filed now
A group within the global minimum tax rules files a GloBE Information Return for each fiscal year. The standard deadline is fifteen months after the last day of the fiscal year, extended to eighteen months for the first year the group is in scope. For a group with a 31 December year end and a first in-scope year of 2024, that produces 30 June 2026, the first occasion on which the return falls due anywhere.
This is a compliance filing, and the tax may be zero. Safe harbours may apply across the group, and the return may still run to thousands of data points. The return describes the group before it calculates anything, and describing a group accurately is a governance task.
Filed once, exchanged
One filing, unless a jurisdiction did not join
The design intent is a single filing. Within the EU, the directive on administrative cooperation adopted on 14 April 2025 lets the return be filed by the ultimate parent entity or a designated filing entity and then exchanged between tax authorities, so it need not be repeated in each member state where the group has an entity. Member states were to transpose it by 31 December 2025.
Internationally the picture is close to that but not complete. The OECD published a common understanding on central filing on 18 May 2026, under which participating jurisdictions either waive penalties or do not enforce their local filing obligation where the return has been filed centrally by the deadline. Four jurisdictions with the minimum tax in effect for 2024 had not joined as of 12 May 2026, and a group with entities there may have to file locally as well. Notification obligations continue to apply in their own right, and they are frequently the first thing a group misses, because a notification is short and falls due before anyone is thinking about the return.
Two lists
The return asks for the list you assumed you had
The first part of the return is not a computation. It identifies the group's constituent entities, the jurisdiction of each, the ownership structure that connects them and the status of entities treated differently by the rules, including those excluded from them. A schema will not accept a missing entity, and it will not query an ownership percentage that has been stale since a reorganisation two years ago. It records what it is given. Most entity lists have never been held to that standard, because a small inaccuracy in a dormant company's details has never had a consequence.
A fund or private-equity group meets this with two lists that were never designed to agree. The consolidation system holds what is consolidated, which leaves out dormant companies, entities held for sale, joint ventures and vehicles carried at fair value. The company secretarial register holds what legally exists, which sometimes includes entities struck off eighteen months ago and rarely reflects last quarter's transfer of shares between two subsidiaries. The return needs the second list, checked against the first.
The reconciliation
Explain the differences before the schema finds them
Take the entity list from the consolidation and the entity list from the register as at the fiscal year end, and account for every difference in writing: incorporated during the year, acquired, disposed of, liquidated, dormant, not consolidated for a stated reason. Give the exercise an owner and a completion date. The differences are the interesting part, because each one is either a data error or a fact the tax team did not have.
Dates are what stop the reconciliation being redone from scratch each year. Record ownership percentages with the dates from which they took effect, so a mid-year transfer can be seen and not inferred from a current figure. Record the date each entity ceased to exist alongside the date it was incorporated, because a return for a past year needs the group as it stood then.
In Alethia
One register, held as a history
Alethia keeps entities with their jurisdictions, their ownership and the officers and documents attached to them, together with compliance obligations carrying due dates and an audit trail of every change. Because ownership is recorded with effective dates and not overwritten, the register can be read as it stood at a past year end, which is the form the return requires, and the structure chart an adviser is shown comes from the same data as the entity list. Alethia does not compute effective tax rates, prepare the return or file it with any authority. It is where the preparer gets the entity population and the ownership chain to start from, and where next year's preparer can see what last year's concluded.
Questions
What groups ask about the first return
Is 30 June 2026 the deadline everywhere?
No. It is the eighteen-month transitional deadline for a first in-scope fiscal year ending 31 December 2024, and many jurisdictions apply it. Others set earlier registration or notification dates, brought local minimum tax returns forward, or announced extensions to particular forms. The date has to be checked jurisdiction by jurisdiction for the entities the group actually has.
If we file centrally, is the local obligation dealt with?
Usually, but conditionally. Relief depends on the jurisdiction having joined the central filing arrangement or, within the EU, on the exchange framework operating. Where a jurisdiction has not joined, a local filing may still be required, and notification obligations are separate from the return in any case.
Is the consolidation not already the definitive entity list?
It is definitive about what is consolidated, which is a narrower question. Dormant companies, entities held for sale, joint ventures and vehicles carried at fair value can all sit outside it while remaining entities the group owns. The reconciliation between the two lists is the work, and it is easier before the filing window than during it.
Two of our companies were liquidated during the year. Where do they sit?
Whether a particular company is a constituent entity for a given fiscal year is a question for the adviser. The preparer needs two unambiguous dates from the register: the date each entity was incorporated and the date it ceased, so the group can be read as it stood at the year end and not as it stands on the day the return is prepared.
The entity list is the first page of the return
Compare the consolidation and the register at the year end, explain every difference in writing, and record ownership with effective dates, so next year the reconciliation starts where this one finished.