When a multinational enterprise (MNE) group has a constituent entity in New Zealand under the GloBE rules, they must complete a GloBE registration.
The ultimate parent entity’s (UPE) fiscal year end determines when the MNE group must register by and complete other GloBE filing requirements.
When an MNE group must register
The GloBE rules apply to fiscal years beginning on or after 1 January 2025. An MNE group has 6 months to register after the end of the first fiscal year that the GloBE rules apply to the group.
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
Each MNE group only needs 1 registration
Each MNE group only needs 1 registration for all its constituent entities in New Zealand. A designated New Zealand constituent entity must register and complete the notification for all New Zealand constituent entities. The registration must identify all New Zealand constituent entities.
Change of designated NZ constituent entity
If there is a change to the designated New Zealand constituent entity, that constituent entity must de-register and the new designated New Zealand constituent entity should register.
In-scope for part year
MNE groups must register even when they are only in scope for a part year. This includes when an MNE group is disposing of or dissolving its New Zealand operations.
Joint ventures
Do not include joint ventures (JVs) as a constituent entity in the registration if they’re accounted for under the equity method in the MNE group’s consolidated financial statements. These joint venture details will be provided in the GloBE information return (GIR).
Include JVs as a constituent entity if they are included in the MNE group’s consolidated financial statements on a line-by-line basis (in other words, if they are consolidated).
Permanent Establishments
A New Zealand permanent establishment of an entity which is included in the MNE group’s consolidated financial statements on a line-by-line basis, is a separate constituent entity and should be included in the registration.
Change of UPE
If the UPE of the designated constituent entity changes during the 1st fiscal year of registration, as part of the notification process submit your registration details with the 1st UPE’s information and details of the new UPE.