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12 June 2026

Portugal extends deadline for filing Pillar Two GloBE Information Return and Top-up Tax assessment return for FY2024

  • An order issued on 3 June 2026 extends by three months the deadline for filing the GloBE Information Return and the Top-up Tax assessment return for FY2024 in Portugal.
  • The new filing deadline is 30 September 2026, applicable to fiscal years ended between 31 December 2024 and 31 March 2025.
  • The extension aligns with international guidance permitting temporary relief from local filing obligations in certain circumstances.
  • Multinational enterprise groups with constituent entities in Portugal should factor the extended deadline into their compliance timelines and consider appropriate support to ensure timely Pillar Two filing and payment obligations are met.
 

Executive summary

The Secretary of State for Tax Affairs issued Order no. 76/2026 on 3 June 2026 to postpone the deadline for filing the Global Anti-Base Erosion (GloBE) Information Return (GIR) and the Top-up Tax (TuT) assessment return for FY2024.

The new deadline is 30 September 2026 and applies to fiscal years ended between 31 December 2024 and 31 March 2025.

Background

Portuguese constituent entities are responsible for filing the GIR, which should be filed by a local designated entity if more than one local entity exists. However, this responsibility is waived if the ultimate parent company or a designated filing entity files the GIR, provided that the entity filing the return is located in a country or jurisdiction with which Portugal has a qualified competent authority agreement.

Portuguese constituent entities liable for paying TuT under the Income Inclusion Rule, the Undertaxed Profits Rule or the Qualified Domestic Minimum Top-up Tax must file a TuT assessment return and pay the associated tax. This is performed by the local designated entity if more than one local entity exists.

Under the general legal framework, GIRs must be filed 18 months after the end of the fiscal year, which would mean a deadline of 30 June 2026 for fiscal years ending on 31 December 2024.

Filing deadline extended

In deciding to extend the deadline for filing the Portuguese GIR and TuT assessment return, the Portuguese Secretary of State for Tax Affairs took into consideration (1) the complexity of Pillar Two compliance, (2) the coordination required within multinational enterprise (MNE) groups in-scope of the Pillar Two framework and (3) the Organisation for Economic Co-operation and Development (OECD) common understanding on the use mechanisms available under domestic laws to waive penalties or suspend enforcement of local GIR filing obligations in certain circumstances. (For more on the OECD common understanding, see EY Global Tax Alert, Portugal's Tax Authority explains impact on Portuguese companies of OECD's recent update regarding Pillar Two filings, dated 27 May 2026.)

The deadline has been extended to 30 September 2026 for fiscal years ending between 31 December 2024 and 31 March 2025.

Implications

MNE groups with constituent entities in Portugal should consider the extended filing deadline in respect to fiscal years ending by 31 March 2025.

Affected entities should consult with their tax advisors for help with navigating these new updates and supporting Pillar Two compliance.

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Contact Information

For additional information concerning this Alert, please contact:

Ernst & Young, S.A., International Tax and Transaction Services

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

Document ID: 2026-1260

 

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