Automatic exchange of information under Pillar Two: updated list of GIR MCAA signatories

On 15 April 2026, the OECD updated the list of jurisdictions that have signed the GIR MCAA in connection with the exchange of information under Pillar Two. According to the latest overview, the list currently includes 31 jurisdictions. The updated list is available on the OECD website.

The GIR MCAA is a key tool for the implementation of the global minimum tax, as it enables the automatic exchange of GloBE Information Return data between tax administrations of signatory jurisdictions. The breadth of the network of signatories is important for multinational groups when designing their Pillar Two reporting and compliance strategy, in particular for:

• determining the jurisdiction in which the GIR will be filed (the “filing entity”),
• assessing whether all relevant countries in which the group operates are covered by automatic exchange,
• identifying any additional local notification or reporting requirements in non‑signatory jurisdictions.

Certain EU Member States have not yet signed the GIR MCAA and have also not transposed directive DAC 9 into their domestic legislation. This includes, in particular, Bulgaria, Cyprus, the Czech Republic and Malta.

With June 2026 approaching – when groups will be filing the first-ever GIR for 2024, benefitting from an extended filing deadline of 18 months – it is crucial for in-scope groups to ensure they have clarity on where the GIR will be filed, how data will be collected and which tax administrations will receive the information through automatic exchange.

Recommendation for clients

We recommend that clients:

• review the current list of GIR MCAA signatories and compare it with the countries in which their group operates,
• adjust their internal Pillar Two processes accordingly (including determining the GIR “filing entity”),
• verify whether any additional local requirements may arise in non‑signatory jurisdictions.

If you need advice on Pillar Two or assistance with performing the calculations and preparing the required filings, we will be happy to help.