Pillar Two: It has been approved the declaration to communicate the submission to the Global Minimum Tax

This declaration Model 62 (registration declaration) was approved by Ordinance no. 290/2025/1, of 2 September, and results from Portugal's implementation of Pillar Two of the OECD/G20 through Law no. 41/2024, of 8 November, which transposed Council Directive (EU) 2022/2523 of 14 December 2022.

This declaration must be submitted, electronically, by each entity located in Portugal that is part of the group subject to the GMT. However, a local entity can be appointed for this purpose, with the others being notified by the Portuguese Tax Authority to confirm such appointment.

Multinational groups must indicate the starting period in which international activity occurred, while large national groups must refer to the first fiscal year in which they became subject to the GMT.

Taxpayers subject to the GMT already in 2024 must comply with this communication obligation within 12 months after the end of that period. For those with a fiscal year equal to the calendar year, this declaration must be submitted by 31/12/2025 (regardless of whether it is a business day or not).

Those that become subject to the GMT in 2025 or subsequent periods must fulfil this obligation by the last day of the ninth month after the end of the relevant fiscal year (also regardless of whether it is a business day or not).

Failure to submit or late submission of this declaration is subject to a penalty ranging from EUR 5,000 to EUR 100,000, increased by 5% for each day of delay. However, these fines may be waived for fiscal years starting until December 31, 2026, and ending before July 1, 2028, if it is concluded that the entity acted in good faith or that the infraction does not result in a reduction of the amount of tax due in that or subsequent fiscal years.

Finally, it should be noted that the approval of the declaration of information on the complementary tax and the declaration of tax settlement is still awaited.