Portugal postpones Global Minimum Tax reporting deadline

Order no. 76/2026-XXV, of 3 June, issued by the Secretary of State for Tax Affairs, has been published, extending the deadline for filing the returns provided for in article 46 (1) of the RIMG, approved by Law no. 41/2024, of 8 November, for the 2024 fiscal year, from 30 June to 30 September 2026.

This extension applies to multinational enterprise groups and large-scale domestic groups whose fiscal year ended between 31 December 2024 and 31 March 2025, allowing them to comply with these reporting obligations without any additional charges or penalties.

The returns concerned are the top-up tax information return, corresponding to the GloBE Information Return (GIR), and the tax assessment return, provided for in article 45 (1) (b) and (c) of the RIMG.

This measure takes into account the particular complexity that compliance with these reporting obligations entails for the groups concerned, namely in terms of the coordinated action required within multinational enterprise groups and large-scale domestic groups.

It should also be noted that Law no. 26/2026, published on 3 June, amended article 45 (1) (b) mentioned above, in order to clarify that, even where a local entity has been designated to comply with the obligations in question in Model 62 (in field 04), that entity is exempt from filing the GIR where it has indicated in the same return (in field 12) that the GIR would be submitted centrally in the jurisdiction of the ultimate parent entity. However, if this information is not received under the exchange of information obligations between cooperating States, the Portuguese Tax Authority may notify the designated local entity to file the GIR within three months from such notification.

It should be recalled that the RIMG, which transposed Council Directive (EU) 2022/2523 of 14 December 2022 into Portuguese law, based on the OECD Pillar Two Model Rules, establishes a minimum effective tax rate of 15% 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, in the consolidated financial statements of its ultimate parent entity, in at least two of the four immediately preceding fiscal years.