The ultimate parent entity’s (UPE) fiscal year end triggers the timing for registration (and other Pillar 2 filing requirements).
When an MNE group must register
Sections 78H(1) and (3) of the Tax Administration Act 1994 require a multi-national enterprise (MNE) group to register 6 months after the end of the 1st fiscal year when it has a constituent entity in New Zealand under the applied Global Anti-Base Erosion (GloBE) rules.
The GloBE rules in New Zealand apply to fiscal years beginning on or after 1 January 2025. An MNE group has 6 months to register after the end of their fiscal year, when that year began after 1 January 2025 (or 6 months after the end of the 1st year when the rules apply).
For example, an MNE with a fiscal year ending:
- 31 December 2025 must register by 30 June 2026
- 31 March 2026 must register by 30 September 2026
- 30 June 2026 must register by 31 December 2026
Single registration for each MNE group
There will be a single registration for each MNE group with constituent entities in New Zealand. A designated New Zealand constituent entity will register and complete the notification and reporting on behalf of the other New Zealand constituent entities.
If there is a change to the designated New Zealand constituent entity, that constituent entity must de-register. This should be followed by registering the new designated New Zealand constituent entity.
Registration and notification process
The designated New Zealand constituent entity (or the UPE for New Zealand-owned MNE groups) can register for the GloBE account in myIR from mid-March 2026. The registration will include the required notification on behalf of all New Zealand constituent entities for the group.
To register you’ll need the following details:
- New Zealand constituent entity applying – name and IRD number
- ultimate parent entity – name, jurisdiction of tax residence and Tax Identification Number (TIN)
- names and IRD numbers of all New Zealand constituent entities in the MNE group
- name of the entity that will file the globe information return (GIR), their TIN and jurisdiction where it will file the GIR
- start and end dates of the ultimate parent entity’s fiscal year
- identification of any New Zealand constituent entities of the MNE group that are intermediate parent entities
- identification of any New Zealand constituent entities of the MNE group that are partly owned parent entities (where the other part of the ownership is a 3rd party)
- contact details of the designated New Zealand constituent entity
- tax agent details.
The notification made during registration will remain current until changes are made (a standing or continual notification). If there are changes to the notification, this will be done in the GloBE account.
Tax agent linking
A tax agent can complete the registration and other GloBE filing requirements where they are not linked to the customer’s other accounts. The GloBE account will be a separate account type in myIR the tax agent can link to. This tax agent can be different to other tax agents associated to the customer. This is current practice in myIR.