19 December 2025
Background
As part of our ongoing monitoring of the Global Minimum Tax Regime (GMTR), we have previously published several alerts regarding both the adaptation of financial statement templates and the regime itself, which can be consulted at the following links:
- Tax Alert | Global Minimum Tax Regime (RIMG), dated 21/11/2024;
- Tax Alert | Alteração aos Modelos de Demonstrações Financeiras, dated 26/02/2025;
- Tax Alert | Model 62 Declaration – First Step in the Global Minimum Tax Regime (Pillar Two), dated 04/09/2025.
In this context, Order No. 158/2025-XXV, issued by the Secretary of State for Tax Affairs, has been published, introducing an exceptional extension of the deadline for the first filing of Model Return 62 under the GMTR.
This Order follows the approval of the official template of Model Return 62 by Ordinance No. 290/2025/1 of 2 September, and takes into account, in particular, the complexity associated with complying with this new reporting obligation, as well as the delay in the availability of the respective application on the Portuguese Tax Authority’s Portal (Portal das Finanças).
Extension of the deadline
With regard to the 2024 tax year, the Order establishes that the return provided for in paragraph (b) of No. 3 of Article 46 of the GMTR (Model Return 62) may be submitted, without any surcharges or penalties, by the last day of the 15th month following the end of the relevant tax year, even if that date does not fall on a business day.
This extension applies to constituent entities whose tax year ended between 31 December 2024 and 31 March 2025.
By way of example, where the tax year ends on 31 December 2024, the final deadline for filing Model Return 62 will be 31 March 2026.
Practical implications
This measure grants multinational groups and large domestic groups covered by the GMTR additional time to ensure the necessary coordination between group entities, improve the quality of the information reported and mitigate the risk of errors in completing the return, effectively benefiting from an additional period of approximately three months compared to the initially applicable deadline (31 December 2025).
The Order does not amend the substantive rules of the GMTR, being limited to the establishment of a transitional procedural measure applicable exclusively to the first filing of Model Return 62.
We remain, of course, at your disposal should you require specialised support in tax and accounting matters in this area.
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The above information is not intended to be an exhaustive analysis of all the changes to the current legal regime, but a selection of those that we believe to be the most relevant, and does not dispense with the consultation of our Company and/or diplomas to which they refer.
For more information contact: Catarina Breia (+351 91 7575 832 or cbreia@pt-nexia.com) from our Tax Department.
