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Portugal grants additional time for the submission of Model 62 filing (Pilar Two) in regards FY2025

Portugal - 

Order No. 114/2026-XXV, of 1 September has been published, extending the deadline for filing the Model 62 return in respect of fiscal year 2025, allowing it to be filed, without any surcharges or penalties, until the last day of the 12th month following the end of the relevant fiscal year.

This extension applies to constituent entities whose 2025 fiscal year ended between 31 December 2025 and 31 March 2026, regardless of whether the relevant deadline falls on a business day or not.

Accordingly, where the fiscal year coincides with the calendar year, the deadline for filing the Model 62 return in respect of fiscal year 2025 is extended from 30/09/2026 to 31/12/2026.

The decision considers the experience gained during the first filing campaign for the Model 62 return, relating to fiscal year 2024, during which inaccuracies were identified in the completion of the return, with the present extension aiming to reduce errors in complying with the reporting obligations relating to fiscal year 2025.

The extension also takes into account the coordination with the remaining reporting obligations under the Global Minimum Tax Regime (RIMG), considering that the Model 63 and Model 64 returns relating to fiscal year 2024 may be filed until 30 September 2026, as previously reported, pursuant to Order No. 76/2026-XXV, of 3 June.

It should be recalled that the Model 62 return must be filed electronically with the Portuguese Tax Authorities in order to report the commencement period of the entity’s liability under the RIMG, approved by Law no. 41/2024, of 8 November, which transposed Directive (EU) 2022/2523 (OECD Pillar Two), and applies to constituent entities located in Portugal that are part of a multinational enterprise group or a large-scale domestic group with annual revenues equal to or exceeding EUR 750,000,000, including the revenues of entities excluded from the RIMG, as reflected in the consolidated financial statements of their ultimate parent entity in at least two of the four fiscal years immediately preceding the relevant fiscal year.