经济数字化带来的税收挑战——GloBE信息报告（2025年1月）：BEPS包容性框架

Tax Challenges Arising fromtheDigitalisation oftheEconomy – GloBEInformation Return (January 2025) Inclusive Framework onBEPS OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arisingfrom the Digitalisationof the Economy – GloBEInformation Return(January 2025) INCLUSIVE FRAMEWORK ON BEPS This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty overany territory, to the delimitation of international frontiers and boundaries and to the name of any territory, city or area. ISBN 978-92-64-85453-6 (PDF) Photo credits:Cover © ninog – Fotolia.com Corrigenda to OECD publications may be found at: https://www.oecd.org/en/publications/support/corrigenda.html.© OECD 2025 Attribution 4.0 International (CC BY 4.0) This work is made available under the Creative Commons Attribution 4.0 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 arguments employed inthis adaptation should not be reported as representing the official views of 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 and forany 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 this licence shall be settled by arbitration in accordance with the Permanent Court of Arbitration (PCA) Arbitration Rules 2012. The seat of arbitration shallbe Paris (France). The number of arbitrators shall be one. Table of contents Introduction4Annex A1. Data points131 MNEGroup Information142 Jurisdictional safe harbours and exclusions–Jurisdictional schedules 183 GloBE Computations22Annex A2. Explanatoryguidance421 MNE Group Information442 Jurisdictional Safe Harbours and Exclusions543GloBE Computations60Annex B.Notification that the GIR will be received under Exchange ofInformation93Annex C. Transitional Penalty Relief97 Introduction Overview 1.The GloBE Model Rulesprovide for the development of a standardised GloBEInformation Return (GIR). The GIR contains the information a taxadministration needs toperform an appropriate risk assessment and to evaluate the correctness of a Constituent Entity(CE)’s Top-upTax liability. In particular, Article 8.1.4 of the GloBE Model Rules provides anoutline of the information items to be included in the GIR. The rules also provide that this listshall be further specified, expanded or restricted in accordance with the GloBE ImplementationFramework,including through the development of simplified reporting procedures.Thisdocument sets out astandard template for the GIR that incorporates the edits that have beenagreed by the Inclusive Frameworkon BEPS (“Inclusive Framework”)in the context of Article8.1.4. 2.In developing the data points and explanatory guidance that are used for the GIR,theInclusive Framework has sought to strike a balance between providing tax administrations withthe data they need to undertake adequate compliance activities, while limiting the cost ofcompliance for MNEGroups. In particular, the main objective of theInclusive Framework indeveloping this standard template for the GIR is to ensure that the information and taxcalculations that an MNEGroup is required to file under the GIR are sufficiently comprehensiveto allow tax administrations to perform an appropriate risk assessment and to evaluate thecorrectness of a CE’s tax liability under the GloBE Rules. At the same time, the InclusiveFramework has sought to avoid imposing unnecessary information collection, computation andreporting requirements on MNE Groups or exposing taxpayers to multiple, uncoordinatedrequests for further information in each jurisdictionthat has implementedeither the IncomeInclusionRule(IIR),the UTPR or both(“Implementing Jurisdiction”)or that has onlyimplementeda QDMTT(“QDMTT-only Jurisdiction”).The agreement on a standardisedinformation return does not preclude a tax administration from requesting necessary supportinginformation in follow-up requests to verify compliance with the GloBE Rules under theirdomestic law. 3.The obligation to prepare a GIR is separate from the requirement to declare and paytaxes under a tax return. The operation of tax return filing and payment obligation rules is left tothe determination of eachImplementingJurisdiction and is gene