28 May 2026
Background
As part of our ongoing monitoring of the Global Minimum Tax Regime (“GMTR” / Pillar Two), we have previously published several alerts regarding both the adaptation of financial statement templates and the reporting obligations associated with the regime, which can be consulted at the following links:
- Tax Alert | Global Minimum Tax Regime (GMTR), dated 21/11/2024;
- Tax Alert | Amendments to Financial Statement Templates, dated 26/02/2025;
- Tax Alert | Model Return 62 – First Step in the Global Minimum Tax Regime (Pillar Two), dated 04/09/2025;
- Tax Alert | Exceptional Extension of the Deadline for Filing Model Return 62, dated 19/12/2025.
Following these developments, the Portuguese Tax and Customs Authority (“PTA”) issued, on 25 May 2026, guidance on the implementation in Portugal of the common understanding recently published by the OECD regarding the centralised filing and exchange of information of the GloBE Information Return (“GIR”), referred to in Portugal as the return concerning top-up tax information.
These guidelines are particularly relevant for multinational groups and large domestic groups within the scope of the GMTR, approved by Law no. 41/2024 of 8 November, with reporting obligations in Portugal regarding the 2024 tax year.
OECD common understanding and centralised filing of the GIR
The OECD confirmed that 37 jurisdictions have implemented a qualified Income Inclusion Rule (“IIR”) or a Qualified Domestic Minimum Top-up Tax (“QDMTT”) with effect from the 2024 tax year.
In this context, the GIR relating to the 2024 tax year must, as a rule, be filed by 30 June 2026. Subsequently, the jurisdiction responsible for the centralised filing will exchange the relevant information with the remaining implementing jurisdictions by 31 December 2026.
Recognising the operational challenges associated with the practical implementation of this mechanism, namely delays in the availability of local filing portals or in the activation of information exchange relationships, participating jurisdictions agreed that penalties related to the failure to file the GIR locally may be waived, provided that:
- the GIR is centrally filed in a jurisdiction included in the list annexed to the OECD common understanding;
- the corresponding local notification is submitted within the applicable deadline.
Relevance for Portugal
For Portuguese purposes, the PTA clarified that groups within the scope of the regime must ensure that Model Return 62 correctly identifies the jurisdiction where the GIR will be centrally filed.
It should be recalled that Model Return 62, approved by Ordinance no. 290/2025/1 of 2 September, is intended to comply with the reporting obligation established under Article 45 of the GMTR.
Accordingly:
- where a Model Return 62 has already been filed indicating a jurisdiction not included in the list annexed to the OECD common understanding, an amended return should be submitted identifying a jurisdiction included in that list by the applicable GIR filing deadline;
- where Model Return 62 has not yet been filed in respect of the 2024 tax year, it should be submitted by the legal deadline applicable to the GIR filing.
For groups whose tax year coincides with the calendar year, the relevant deadline is 30 June 2026.
In any event, the GIR must effectively be filed, within the applicable deadline, in the jurisdiction indicated in Model Return 62, and it will subsequently be the responsibility of that jurisdiction to ensure the timely exchange of information with the remaining relevant jurisdictions.
Confirmation of the designated local entity
Where Model Return 62 is filed or amended by a designated local entity, completion of the designation confirmation procedure provided for in Article 3 of Ordinance no. 290/2025/1 must also be ensured.
Under the terms of the Ordinance, the remaining group entities located in Portugal are electronically notified through their reserved area of the Portuguese Tax Authority’s Portal in order to confirm the designation.
On this matter, we also refer to our Tax Alert of 19 December 2025.
Recommended actions
Groups within the scope of the GMTR with a presence in Portugal should therefore:
- Confirm whether Model Return 62 relating to the 2024 tax year has already been submitted;
- Verify whether the jurisdiction indicated for the centralised filing of the GIR is included in the list annexed to the OECD common understanding;
- Submit an amended Model Return 62, where necessary;
- Ensure confirmation of the designation, where applicable;
- Ensure the filing of the GIR in the indicated jurisdiction by 30 June 2026, for groups whose tax year coincides with the calendar year.
Portugal is included in the list annexed to the OECD common understanding as an expected jurisdiction for the purposes of the centralised filing of the GIR before 31 May 2026. Nevertheless, groups should continue monitoring the effective operational availability of the portal and the activation of the relevant information exchange relationships.
The recent guidance issued by the PTA regarding the centralised filing mechanism of the GIR provides important operational clarification regarding compliance with the reporting obligations established under the GMTR / Pillar Two framework, particularly concerning the interaction between Model Return 62 and the centralised filing of the GIR.
We remain, of course, at your disposal should you require specialised support in tax and accounting matters in this area, namely regarding the assessment of reporting obligations under the GMTR / Pillar Two framework.
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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.
