9 June 2026
Background
The SEAF Order No. 76/2026-XXV, dated 3 June 2026, was published, extending the deadline for filing the returns provided for in paragraph 1 of Article 46 of the Global Minimum Tax Regime (“RIMG”), with respect to the 2024 fiscal year.
For further information regarding the RIMG, the GloBE Information Return (“GIR”) and the central filing mechanism, please refer to our Tax Alert of 28 May 2026.
Extension of the filing deadline
The SEAF Order No. 76/2026-XXV establishes that the returns provided for in Article 46 of the RIMG, relating to the 2024 fiscal year, may be submitted, without the application of penalties, until 30 September 2026.
This option is justified by the acknowledgment of the complexity associated with the implementation of the new reporting obligations arising from Pillar Two, as well as the operational challenges faced by multinational enterprise groups and large-scale domestic groups within the scope of the regime.
Reporting obligations
From the above, entities subject to the RIMG must ensure the submission of the Global Information Return (“GIR”), as well as any other reporting obligations provided for under Article 46 of the regime, within the new deadline established by the Order.
It should be noted that the Order does not amend the content of the reporting obligations nor the substantive requirements established under the RIMG, affecting exclusively the applicable filing deadline.
Recommended actions
The extension now granted provides an additional three-month period for the collection, validation and consolidation of the information required to prepare the returns mandated under the regime.
Therefore, the groups to which this obligation applies should use this additional time to review their internal reporting procedures and ensure timely compliance with their reporting obligations.
Multinational enterprise groups and large-scale domestic groups subject to the RIMG should:
• confirm the reporting obligations applicable to the 2024 fiscal year;
• assess the status of preparation of the GIR and any other returns required under Article 46 of the RIMG;
• update their tax compliance calendars considering the new deadline of 30 September 2026;
• ensure the collection and validation of the information required for the submission of the relevant returns within the prescribed deadline.
We remain available to provide any further assistance in this matter, particularly regarding the assessment of reporting obligations under the RIMG / Pillar Two framework.
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As informações acima não pretendem ser uma análise exaustiva à totalidade das alterações ao regime legal vigente, mas uma seleção daquelas que entendemos serem as mais relevantes, e não dispensam a consulta da nossa Empresa e/ou diplomas às quais as mesmas se referem.
Para mais informações contacte: Catarina Breia (+351 91 7575 832 ou cbreia@pt-nexia.com) do nosso Departamento Fiscal.
