Recital (16)

In implementing this Directive, Member States should use the Multilateral Competent Authority Agreement on the Exchange of GloBE Information and its commentary, the OECD Model Rules and the explanations and examples in the Commentary to the Global Anti-Base Erosion Model Rules (Pillar Two) released by the OECD/G20 IF on BEPS, as well as the GloBE Implementation Framework, and any updates thereto, as a source of illustration or interpretation in order to ensure consistency in application across Member States to the extent that those sources are consistent with this Directive, Directive (EU) 2022/2523 and Union law. Consequently, the OECD/G20 IF on BEPS instructions for the filing of the standard template, such as the introduction and explanatory guidance to the GIR, including the basis for information reported in the GIR and transitional simplified jurisdictional reporting framework (for fiscal years beginning on or before 31 December 2028, but not including a fiscal year that ends after 30 June 2030), should, to the extent that those sources are consistent with this Directive and Union law, be used as a source of illustration and interpretation for the MNE groups to file the Top-up tax information return in order to ensure consistency of application. It is therefore appropriate to supplement Directive 2011/16/EU with an additional annex that contains a standard template, in line with the standard template developed by the OECD/G20 IF on BEPS, for the filing of the Top-up tax information return under Directive (EU) 2022/2523, as provided for by this Directive.