Pillar Two: the first GIR exercise in key jurisdictions

The GIR debut

During 2025, the jurisdictions that transposed Pillar Two earliest started receiving the first real GloBE Information Return. What was observed in early reviews sets the standard LatAm groups will face in 2026.

Most contested items

1. Adjusted Covered Taxes

• Deferred tax reclassification.
• Treatment of DTAs (Deferred Tax Assets) generated by pre-Pillar Two losses.
• Push-Down Accounting adjustments in acquisitions.

2. GloBE Income

• Elimination of non-cash items (real estate revaluations).
• Stock-based compensation treatment.
• Reversal of inflation adjustments in high-inflation jurisdictions (Argentina, Venezuela).

3. Substance-based Income Exclusion (SBIE)

• Payroll and tangible asset verification.
• Exclusion of operating-leased assets.
• Correct application of transitional relief (10%/8%/6% over 10 years).

Lessons for LatAm groups

1. The ERP must generate the full GIR dataset: SAP S/4HANA with Pillar Two module or equivalent.
2. Pre-filing external audit: identify gaps before the administration does.
3. Document elections: filing positions taken in the first GIR are hard to reverse.
4. Model cash impact: QDMTT can generate substantial cash tax in jurisdictions historically at 0%.

LatAm calendar

Mexico (UTPR in force), Colombia (technical studies), Brazil (CBS reform integrated with GMT), Chile (under consultation) will reach the first GIR in 2026-2027. The European learning curve is the best reference.