New Zealand’s GloBE rules apply to multinational enterprise (MNE) groups with a constituent entity in New Zealand, and global annual revenue of more than EUR750 million in at least 2 of the past 4 years.
When the GloBE rules apply
The GloBE rules apply to fiscal years beginning on or after 1 January 2025.
The ultimate parent entity’s (UPE) fiscal year-end determines the timing for GloBE registration and other filing requirements.
Registering for a GloBE account
A designated New Zealand constituent entity must register for a GloBE account for the MNE group, within 6 months of the end of the 1st fiscal year that the GloBE rules apply to the group. You can register now in myIR.
Registration includes details of your GloBE notification.
Not registering or providing an accurate notification could result in a penalty of up to $100,000.
Side-by-Side Package
The Side-by-Side (SbS) Package makes changes to the GloBE rules. New Zealand has adopted these changes.
- The Simplified ETR Safe Harbour is available for fiscal years commencing on or after 1 January 2026.
- The Transitional CbCR Safe Harbour is available for an additional year (now covering fiscal years beginning on or before 31 December 2027 but not including a fiscal year that ends after 30 June 2029).
- The Substance-based Tax Incentive Safe Harbour is available for fiscal years commencing on or after 1 January 2026.
- The Side-by-Side Safe Harbour and UPE Safe Harbour are available for fiscal years starting on or after 1 January 2026 for MNEs with a fixed date fiscal year end (for example, 31 December). They are available for fiscal years starting on or after 26 December 2025 for MNEs with a 52 or 53-week fiscal year ending on the same day of the week each year (for example, the last Thursday in December).
Read more about the SbS Package on the OECD’s website.
Global minimum tax: Understanding the Side-by-Side package (oecd.org)
The OECD guidance Tax Challenges Arising from the Digitalisation of the Economy – Global Anti-Base Erosion Model Rules (Pillar Two), Side-by-Side Package (‘the Side-by-Side Package’) was published on 5 January 2026.
Side-by-Side package (oecd.org)
Information about the GloBE rules
You can read more about the GloBE rules on our Tax Technical website.
Tax Information Bulletin vol 36 no 4, May 2024
The OECD website has more information on Pillar 2.
Global Anti-Base Erosion Model Rules (Pillar 2) (oecd.org)
Faqs on model globe rules (oecd.org)
Read background information in this 2025 news release from the OECD.
Contact us
If you have any questions, you can email us.