Executive summary

On 14 January 2026, Gibraltar signed the Multilateral Competent Authority Agreement on the Exchange of Global anti-Base Erosion (GloBE) Information (GIR MCAA). Subject to conditions, this will exempt an multinational enterprise group (MNE Group) from filing a GloBE Information Return (GIR) in Gibraltar if the MNE Group is filing a GIR in another jurisdiction that is also a signatory to the GIR MCAA.

Exemptions from filing due to Qualifying Competent Authority Agreement in place

MNE Groups within the scope of Pillar Two are exempt from filing a GIR in Gibraltar if the MNE Group is filing the GIR in another jurisdiction that has a Qualifying Competent Authority Agreement (QCAA) in effect with Gibraltar. Although Gibraltar is now a signatory to the GIR MCAA, arrangements must still be made for Gibraltar to have a QCAA in effect with any of the other GIR MCAA signatories.

There are currently 26 signatories to the GIR MCAA, as listed here by the Organisation for Economic Co-operation and Development (OECD).

If an MNE Group is applying the exemption, the MNE must file in Gibraltar:

• An annual notification, which is due no later than three months before the deadline that would otherwise apply to the GIR
• A Gibraltar Top-up Tax Return (Form GMTA1)

The Gibraltar Top-up Tax Return is intended to be a simple, high-level return. The form to be used for the return (Form GMTA1) has not yet been published, however. For further details, see Global Tax Alert, Gibraltar to introduce Pillar Two registration and local Top-up Tax Return, dated 16 December 2025.

Implications

MNE Groups should prepare for these changes by (1) ensuring they understand the implications of the GIR MCAA on their filing obligations and (2) establishing processes to meet the new notification and return requirements in Gibraltar.