15 June 2026
Background
Law No. 41/2024, of 8 November, approved the Global Minimum Tax Regime (RIMG), transposing Council Directive (EU) 2022/2523 of 15 December 2022, on ensuring a global minimum level of taxation for multinational enterprise groups and large domestic groups.
In this context, Ministerial Order No. 255/2026/1, of 12 June, was published, approving the Model 63 Return – Information Return on the Top-up Tax (GIR – GloBE Information Return), as provided for in Article 45 of the RIMG.
For a general overview of the RIMG framework, the GIR, the centralized filing mechanism, and the filing extension, please refer to our Tax Alert of 28 May 2026 and Tax Alert 9 June 2026.
Entities in scope
The Model 63 (GIR) Return is intended for entities subject to reporting obligations under the Global Minimum Tax Regime, including multinational enterprise groups and large domestic groups within the scope of the global minimum tax rules. For more details, please see Tax Alert dated 21 November 2025.
Reporting of information
The Ministerial Order approves the official form of the Model 63 (GIR) Return, to comply with the reporting obligations for the top-up tax under the RIMG, in accordance with paragraph 3 of Article 45 of the RIMG.
This return is intended to provide information on the supplementary tax to the Portuguese Tax Authorities, in case of local filing. Please note that paragraph 2 of the RIMG provides for an exemption where the return providing information on the supplementary tax has been filed by the ultimate parent company or by a designated reporting entity located in a jurisdiction where, in the reporting tax year, a qualified agreement is in force between the competent authorities and the State in which the constituent entity is located (central filing).
The reporting of information to the Portuguese Tax and Customs Authority (AT) must be carried out by electronic data transmission, through an XML file, in accordance with the structure and specifications made available on the Tax Authority’s website and set out in the annex to the Ministerial Order.
The return is deemed to be submitted on the date of its electronic filing.
Completion instructions
The completion instructions for the Model 63 (GIR) Return will soon be made available on the Tax Authority’s website, based on the version published by the Organisation for Economic Co-operation and Development (OECD), agreed under the OECD/G20 Inclusive Framework, as well as its Portuguese translation.
Entry into force
The Ministerial Order enters into force and takes effect on the day following its publication, i.e., on 13 June 2026.
We remain, as always, available to provide any further clarification on this matter, in particular regarding the reporting obligations under the Global Minimum Tax Regime (RIMG) and the filing of the Model 63 (GIR) Return.
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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.
