New Zealand · Pillar Two · In force

New Zealand Pillar Two obligations

New Zealand imposes 3 separate filing obligations under Pillar Two. The earliest is GloBE registration and notification, due Within 6 months of the end of the first fiscal year the rules apply. Checked against the authority on 3 October 2026.

Checked 3 October 2026 Primary-sourced 3 separate filing obligations

A six-month registration clock that bites long before any return is due, with a NZ$100,000 exposure attached.

Access gate — clear this before anything can be filed

GloBE account registration

Due within 6 months of the end of the first fiscal year the rules apply — set by the UPE's year end, not the local entity's. Required even if the group is in scope for only part of a year.

What is in force in New Zealand

ChargeLocal nameIn force from
IIRMultinational top-up tax (applied GloBE rules)Fiscal years beginning on or after 1 Jan 2025
UTPRApplied GloBE rulesFiscal years beginning on or after 1 Jan 2025
DomesticDomestic income inclusion rule (DIIR)Fiscal years beginning on or after 1 Jan 2026

The 3 separate filing obligations

GloBE registration and notification

Also: GloBE account

One registration per MNE group covering all its New Zealand constituent entities.

Who files
A designated New Zealand constituent entity
Deadline
Within 6 months of the end of the first fiscal year the rules apply
Channel
myIR — Registration → International exchange of information account → Global Anti-Base Erosion (GloBE)

GloBE registration requirements — Inland Revenue ↗

GloBE information return

Also: GIR

The OECD-format information return.

Who files
The designated New Zealand constituent entity for NZ-headquartered groups
Deadline
18 months after the first fiscal year. IRD advises NZ-headquartered groups to file within 15 months to align with other jurisdictions.
Channel
myIR, XML meeting the OECD GIR XML Schema. MessageRefId and DocRefId must begin with the designated entity's IRD number.

Filing the GloBE information return — Inland Revenue ↗

Multinational top-up tax return

The return assessing multinational top-up tax.

Who files
The designated New Zealand constituent entity
Deadline
20 months after the fiscal year for the first year; 16 months thereafter
Channel
Online return in myIR — available from April 2027

Filing the top-up tax return — Inland Revenue ↗

Penalties

Not registering or providing an accurate notification: up to NZ$100,000. Penalties for late or incorrect filing of the GIR or top-up tax return are not stated by IRD.

What catches groups out in New Zealand

  • The registration clock runs off the UPE's year end, not the New Zealand entity's.
  • IRD has said it will publish GIR submission mechanics only after October 2026, and the top-up tax return is not available in myIR until April 2027.
  • New Zealand has adopted the Side-by-Side package; the transitional CbCR safe harbour now extends to fiscal years beginning on or before 31 Dec 2027.

Recent changes affecting New Zealand

  • 2026-01-01 — New Zealand adopts the OECD Side-by-Side package; the transitional CbCR safe harbour extends to fiscal years beginning on or before 31 December 2027.

All dated changes →

Common questions

What must be filed in New Zealand under Pillar Two?

3 separate obligations: GloBE registration and notification; GloBE information return; Multinational top-up tax return.

When is the GloBE registration and notification due in New Zealand?

Within 6 months of the end of the first fiscal year the rules apply. Filed by: A designated New Zealand constituent entity. Channel: myIR — Registration → International exchange of information account → Global Anti-Base Erosion (GloBE).

When is the GloBE information return due in New Zealand?

18 months after the first fiscal year. IRD advises NZ-headquartered groups to file within 15 months to align with other jurisdictions.. Filed by: The designated New Zealand constituent entity for NZ-headquartered groups. Channel: myIR, XML meeting the OECD GIR XML Schema. MessageRefId and DocRefId must begin with the designated entity's IRD number..

What access is needed before filing in New Zealand?

GloBE account registration. Due within 6 months of the end of the first fiscal year the rules apply — set by the UPE's year end, not the local entity's. Required even if the group is in scope for only part of a year.

What are the penalties in New Zealand?

Not registering or providing an accurate notification: up to NZ$100,000. Penalties for late or incorrect filing of the GIR or top-up tax return are not stated by IRD.

Where this comes from

Every row on this page was checked against the authority's own published page on 3 October 2026. Verified against Inland Revenue pages.

Cite this page

Saurabh Satija, “New Zealand Pillar Two filing obligations”, https://saurabhsatija.com/pillar-two-new-zealand, accessed [date].

Quotation and citation with attribution and a link are welcome. The underlying data is open as JSON and as plain text.

Other Pillar Two jurisdictions

United Kingdom · Ireland · Netherlands · Belgium · Germany · Spain · Italy · Luxembourg

All 21 entries in the tracker →

How many of these are actually yours?

This page shows what New Zealand requires. The scoping tool takes your whole footprint and returns every filing it triggers, in deadline order, with the access prerequisites attached. About thirty seconds.