Tax Alert | Model 62 Declaration – First Step in the Global Minimum Tax Regime (Pillar Two)

September 4, 2025

Framework

The Portaria n.º 290/2025/1, approving the Registration Declaration – Model 62, was recently published in the Diário da República, in accordance with Law n.º 41/2024, of 8 November, which introduced the Global Minimum Tax Regime (RIMG) in Portugal.

As part of our continuous monitoring of the RIMG, we have previously published alerts on the regime, which can be consulted here:

• Tax Alert | Global Minimum Tax Regime (RIMG) – 21/11/2024

This declaration represents the first mandatory compliance step under the OECD/G20 Pillar Two, transposed into national law through Directive (EU) 2022/2523.

Scope

Who is affected?

Model 62 applies to entities located in Portugal that are part of:

• Multinational Groups, or

• Large Domestic Groups

and meet the criterion of annual revenues equal to or exceeding €750 million, in at least 2 of the 4 previous fiscal periods.

What does it entail?

In practice, Model 62 requires:

• Notification to the Tax Authority of the group’s RIMG coverage;

• Identification of the reporting entity or the local designated entity;

• Identification of the ultimate parent or designated entity, including jurisdiction and foreign tax identification number.

Key deadlines

The declaration must be submitted:

• At the last day of the 9^th month after the end of the relevant fiscal year or,

• Up to the last day of the 12^th month after the end of that fiscal year, in relation to the first fiscal year in which the group to which the constituent entity belongs becomes covered by the scope of the RIMG.

In practice this means that for Groups whose reporting period corresponds to the calendar year, until December 31, 2025, when they are covered by Pillar Two from the 2024 financial year onwards, inclusively.

How we can assist?

Model 62 represents the first step in the new reporting and compliance procedure associated with Pillar Two in Portugal. We recognize that this obligation may pose significant challenge for large-scale Portuguese groups, as well as multinational groups covered by Pillar Two, requesting a critical analysis, namely in its scope, its impact, in the definition and implementation of compliance procedures & strategies.

It is also important to review internal reporting and accounting procedures to ensure compliance with  Portaria n.º 41/2025/1 and  Accounting and Financial Reporting Standard 25 Income Taxes (AFRS 25).

We remain, of course, at your disposal should you require specialized tax and accounting support 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.