GIR Final Validation: What to Check in the Last Week

For groups filing GIR for FY2024, the 30 June 2026 deadline is days away. Data is essentially ready - but this is precisely when the risk is highest. Last-minute pressure creates errors that can still be caught, if you know where to look.

1. CE Register - completeness and currency

Most common mistake: entities acquired or disposed of during the year are missing from the register, or the status of a holding entity is outdated. Walk through the CE register chronologically - every structural change between 1 January and 31 December 2024 must be reflected in the GIR.

Also verify that each entity has the correct jurisdiction and role (UPE, IPO, member entity). An error at the CE Register level propagates to every downstream calculation.

2. ETR per jurisdiction - the sanity check

Before filing, review effective tax rates by jurisdiction. ETR well below 15% with no top-up, or ETR above 40% in a jurisdiction with no specific tax anomalies - these are data quality signals, not achievements.

Compare the output against estimates made months ago. Large deviations from earlier projections need an explanation - either the data improved, or an error crept in.

3. Tax reconciliation: current and deferred

Covered taxes must reconcile to the financial data. Check:

Current tax per entity is consistent with the local tax return (or its draft).
Deferred tax is computed using the GloBE method (not always identical to the accounting method).
Return-to-provision items from prior years are correctly classified.

Inconsistencies between the GIR and local returns are a verification risk - tax authorities will compare these numbers.

4. Safe harbour - are conditions still met?

If you are applying Transitional CbCR Safe Harbour for certain jurisdictions, run a final check of the three tests for each. Make sure the CbCR data underlying the tests is final (not working drafts) and that the policies used in the calculations are documented.

A data change (e.g. a revenue restatement in one country) can knock a jurisdiction out of TCSH. Better to catch that now than after filing.

5. Authorizations and filing mechanics

Before submitting: confirm the signatory has a current authorization to file the GIR in the relevant jurisdiction. Where filing is done by the UPE or locally via QDMTT, verify that it is clear who files and on what legal basis in each jurisdiction.

Some jurisdictions required advance notification (e.g. designation of the filing entity). If that step was missed - resolve it with local counsel now, not after the fact.

Bottom line. The last week is not the time to optimize - it is the time for quality control. The five areas above can be reviewed systematically in 2-3 business days. An error caught before filing is cheap. Caught after - significantly more expensive.

Educational content only; does not constitute tax advice. Local deadlines and requirements must be verified with a qualified adviser in the relevant jurisdiction.