GloBE信息申报表（支柱二）XML模式：税务管理用户指南

User Guide for Tax Administrations GloBE Information Return (Pillar Two) XMLSchema: User Guide for Tax Administrations January 2025 This documentand related XML Schema, as well as any dataincluded herein, are without prejudice to the status of orsovereignty over any territory, to the delimitation of international frontiers and boundaries and to the name of anyterritory, city or area. This document was approved by theInclusive Framework on Base Erosion and Profit Shifting on30 October2024andprepared for publication by the OECD Secretariat. Please cite this publication as:OECD (2025),GloBE Information Return (Pillar Two) XML Schema:User Guide for Tax Administrations, OECDPublishing, Paris, Photo credits:Cover © optimarc–Shutterstock.com Attribution4.0 International (CCBY4.0) This work is made available under the Creative Commons Attribution4.0 International licence. By using this work, you accept to be bound by the terms of this licence(https://creativecommons.org/licenses/by/4.0/). Attribution–you must cite the work. Translations–you must cite the original work, identify changes to the original and add the following text:In the event of any discrepancy between the original work and thetranslation, only the text of original work should be considered valid. Adaptations–you must cite the original work and add the following text:This is an adaptation of an original work by the OECD. The opinions expressed and argumentsemployedin this adaptation should not be reported as representing the official viewsof the OECD or of its Member countries. Third-party material–the licence does not apply to third-party material in the work. If using such material, you are responsible for obtaining permission from the third party andfor any claims of infringement. You must not use the OECD logo, visual identity or cover image without express permission or suggest the OECD endorses your use of the work. Any dispute arising under thislicence shall be settled by arbitration in accordance with the Permanent Court of Arbitration (PCA) Arbitration Rules2012. The seat of arbitrationshall be Paris (France). The number of arbitrators shall be one. Foreword This document contains the user guide for the GIR XML schema that supports the automatic exchange ofinformation of GloBE Information Return (GIR) information as part of the implementation of the GlobalMinimum Tax. While the XML schema has been primarily designed to facilitate the exchanges of GIRinformation between tax administrations, the XML schema can also be used for domestic GIR filings, tothe extent permitted under the domestic laws of the relevant jurisdiction. Table of contents Foreword3 Abbreviations and Acronyms5 Introduction7 Structure of the GIR XML Schema and User Guide8 GIR XML Schema User Guide Message Header10ID Type, Excluded UPE ID Type, TIN Type, and Additional Data Point12GloBE Body18Filing Info19General Section22Summary35Jurisdiction Section41GloBE Tax47Overall Computation86Low Tax Jurisdiction119UTPR Attribution123Corrections126 Appendix A129 Abbreviations and Acronyms Introduction Background The Global Anti-Base Erosion (GloBE) Model Rules require the annual filing of a GloBE Information Return(GIR) that provides information on the tax calculations made by an MNE Group under the GloBE Rules. Recognising the benefits of the consistent implementation of the GIR filing requirements, and following apublic consultation process, in July 2023, the Inclusive Framework on BEPS (Inclusive Framework) agreedastandardised GloBE Information Return(GIR)template to be relied upon by all implementingjurisdictions, as well as an approach for disseminating the contents of the GIR amongst such implementingjurisdictions. As part of its work on the facilitation of the implementation of the GloBE Model Rules, and with a view toensuring a consistent, standardised approach to capturing the GIR information, the Inclusive Frameworkon BEPS hasdeveloped a schema in extensible mark-up language (XML) and a corresponding user guide. The GIR XML Schema and User Guide are designed to both facilitate domestic GIR filings, whereverappropriate, and to be the technical format for exchanging GIR information between tax administrations. Structure of theGIR XML SchemaandUser Guide The Schema for exchanges pursuant to theGIRUserGuideisdividedintologicalsectionsbasedontheschema andprovidesinformationonspecificdataelementsandanyattributesthatdescribeeachdataelement. Themain sections of theGIRSchemaUser Guide are: I.The MessageHeaderwiththesender,recipient,messagetype andReporting Fiscal Year;II.TheIDand TINtypes, used forproviding identifyingand TINinformation in relation to CEs,JVs, JV Subsidiaries and UPEs.III.TheGloBEBody, which containsfivesub-sections–a.Filing Info, which corresponds to Sections 1.1 and 1.2 of the GIR and containsinformation identifying the FilingCEand MNE Group;b.General Section(NB the scope of the term is limited in comparison with thedefinition unde