The Portuguese Ministry of Finance has approved Order No. 290/2025/1 of 2 September 2025, Registration Form — Modelo 62, aimed at ensuring compliance with the first reporting obligation under the European Union's (EU's) Minimum Tax Directive.

Background

Law No. 41/2024 of 8 November 2024 introduced in Portugal the 15% Global Minimum Tax rate for multinational enterprise (MNE) group and large-scale domestic groups and transposed into law Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation, based on Organisation for Economic Co-operation and Development's (OECD's) Pillar Two Model Rules

The mentioned law established a set of new reporting obligations in Portugal under Pillar Two, applicable to constituent entities located in Portugal that are part of an MNE group or large-scale domestic groups.

Specifically, constituent entities are required to submit the following declarations to the Portuguese Tax Authorities (PTA):

1. A declaration must be made at the start of the initial phase of international activity by the MNE group or, for domestic groups, the first year of application of the rules. This declaration must also identify the reporting constituent entity, which may be any constituent entity located in Portugal or a designated local entity. The ultimate parent entity (UPE) or a designated entity responsible for filling the GloBE Information Return (GIR) for the group must also be reported.
2. An information return on the top-up tax (i.e., a GIR) must be filed for each fiscal year by the constituent entity or on behalf of the constituent entity by a designated local entity.
3. A tax assessment return must be filed if additional tax is payable in Portugal under Pillar Two rules for a given fiscal year.

Modelo 62

The approved Modelo 62 aims to fulfill the first of the obligations above and must be submitted, as a rule, nine months after the end of the relevant fiscal year, and no later than 12 months after the end of the first fiscal year when a group becomes subject to Pillar Two rules. For groups with a reporting period that aligns with calendar year, this means by 31 December 2025 if they fall under Pillar Two starting from fiscal year 2024.

The ministerial order and the filing instructions of Modelo 62 indicate that groups may elect to submit a single form, through a designated local entity, covering all the constituent entities located in Portugal. The other constituent entities must provide an electronic confirmation via a new functionality on the PTA official website. The declaration is considered submitted on the date of the last confirmation by the constituent entities.

The information included in Modelo 62 should not be modified, except in cases of changes to the group or when previously submitted information needs to be amended, including whenever the group ceases to be subject to Pillar Two. In these cases, a new and complete declaration must be submitted.

Furthermore, Modelo 62 requires providing the identity of the UPE or a designated reporting entity located in a jurisdiction with a qualified information exchange agreement, which will centrally submit the GIR for the group. This includes providing the tax identification number (or equivalent) used in the GIR, the Portuguese tax identification number (if any), jurisdiction, entity name and address for either the UPE or a designated entity.

If there is no qualified information exchange agreement that allows for centralized submission of the GIR in the jurisdiction of the UPE or designated entity, the GIR must (also) be submitted in Portugal.

It is currently unclear under what circumstances and to what extent these new reporting mechanisms will align with EU's DAC 9 directive (Directive on Administrative Cooperation 9), which sets new tax compliance standards regarding the application of the Global Minimum Tax in the EU.

Implications

The approval of Modelo 62 marks the first step in the new compliance and reporting process under Pillar Two and represents a significant challenge for both large Portuguese groups and MNE groups falling within its scope.

It is therefore essential that these groups assess the impact of this new reporting requirement and ensure they are prepared to comply.

Affected entities should consult with their tax advisors for help navigating these new compliance requirements, both in analyzing the financial and tax impact of this new tax regime and in supporting compliance with the resulting reporting obligations.