Indonesia Signs Global Tax Pact GIR MCAA, Multinational Data Exchange Starts 2027

Indonesia has officially joined the global front in the war against tax base erosion by multinational corporations. The Director General of Taxes signed the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA) at the 13th Competent Authorities Conference in Kotor, Montenegro, on 27-29 October 2026.

With this signing, Indonesia is recorded as the 41st signatory of the GIR MCAA, based on the Organisation for Economic Co-operation and Development (OECD) list as of 1 October 2026. The agreement paves the way for automatic cross-border exchange of tax information to support the implementation of the Global Minimum Tax.

The GIR MCAA is fundamentally a data-exchange instrument. The GIR — GloBE Information Return — is a standardized report containing information on multinational enterprise groups and their application of the Global Anti-Base Erosion (GloBE) rules in each jurisdiction where the group operates. Tax authorities need this information to verify that global minimum tax calculations and compliance are correct.

The global minimum tax rules only target multinational groups with annual consolidated gross revenue of at least 750 million euros. Domestic companies that are not part of a multinational group are untouched by this mechanism. The direct targets are Indonesian subsidiaries of global groups meeting that threshold.

Through the Automatic Exchange of Information (AEOI) mechanism, Indonesia's Directorate General of Taxes (DGT) can obtain relevant GIR data from partner jurisdictions without having to request it case by case. Indonesia's participation strengthens access to multinational groups' tax data that has long been hard to reach — particularly for monitoring their compliance with global minimum tax rules.

The GIR MCAA was drawn up under Article 6 of the Convention on Mutual Administrative Assistance in Tax Matters (MAAC), which Indonesia has ratified. Domestically, the GloBE rules are already set out in Finance Minister Regulation No. 136 of 2024, so the national legal foundation is in place before data exchange begins.

When does exchange start? Automatic exchange is scheduled for 2027. But implementation with each partner country will not be automatically simultaneous — it depends on fulfilling notification requirements to the Co-ordinating Body Secretariat and activating exchange relationships between jurisdictions that mutually designate each other as senders and recipients.

There is also good news on reporting efficiency. GIR reporting is centralized: a multinational group may file its GIR through a single qualifying jurisdiction instead of repeating filings in every country of operation. DGT has said the mechanism should ease compliance for companies covered by the global minimum tax while reducing their administrative burden.

The GIR MCAA is part of the OECD/G20 BEPS project — specifically Pillar Two, which sets a global minimum tax rate for large multinationals. Without information exchange, the rule is hard to enforce because each country's tax authority sees only a small slice of a global group's operations. That is where the GIR is key: the standardized report maps where profits are booked, where taxes are paid, and whether the effective rate in each jurisdiction meets the minimum threshold.

At the Kotor conference, the agreement was signed by 40 tax authorities — a rare moment of collective momentum in tax diplomacy. For companies, central filing means a multinational group files its GIR through one parent jurisdiction rather than repeating reports across operating countries. The DGT says the mechanism eases compliance while cutting administrative load.