Extension of the Deadline - Article 45 Global Minimum Tax Regime

We would like to inform you that Order No. 76/2026-XXV has been published, extending the deadline for the submission of the Pillar Two returns provided for in Article 45(1)(b) and (c) of the Global Minimum Tax Regime (RIMG):

• Top-up Tax Information Return (GIR - GloBE Information Return): This return must be submitted by the designated local entity, the designated filing entity, or the Ultimate Parent Entity where any of these entities is located in Portugal, and where the return is not filed in another jurisdiction, as communicated through Form 62.
• Tax Settlement Return (ICNQ-PT): This return is required whenever top-up tax is payable in Portugal. The relevant Group entity responsible for filing the GIR must communicate this fact to the Portuguese entity so that it can comply with this filing obligation.

Note: The approval and publication of the official return form are still pending. This will be necessary to confirm the above interpretation and to clarify whether the return must also be submitted as evidence of the tax assessment even where no tax is payable

This extension applies to Constituent Entities whose fiscal year 2024 ended between 31 December 2024 and 31 March 2025, allowing the above returns to be submitted until 30 September 2026, without any surcharges or penalties.

This measure aims to provide companies with additional time to address the challenges associated with the initial implementation of Pillar Two and to validate the information required for compliance.