The Italian Revenue Agency has approved the annual reporting form for supplementary taxation under Italy's implementation of the OECD's 15% global minimum tax, completing the operational framework for large multinational and national groups.
Italy’s Revenue Agency issued a directive on 6 February 2026, approving the annual declaration form for supplementary taxation under the Global Minimum Tax regime established by Legislative Decree no. 209/2023.
The provision finalises the operational framework initiated by a decree from the Deputy Minister of Economy and Finance dated 7 November 2025, which outlined reporting and payment obligations under Article 53 of the legislative decree.
The Global Minimum Tax implements the international agreement reached within the OECD framework (rules from 14 December 2021) and the EU Council Directive 2022/2523. The mechanism ensures that large multinational and national groups are subject to a minimum effective tax rate, preventing base erosion through excessively low taxation in certain jurisdictions.
Three types of supplementary taxation
Italy’s implementation introduces three distinct taxes:
- Supplementary minimum tax: Applied by Italian parent companies of multinational or national groups when group entities are subject to low tax rates in other jurisdictions.
- Supplementary minimum tax (second type): Levied when Italian group companies must compensate for the absence or insufficiency of equivalent minimum taxation applied abroad.
- National minimum tax: Imposed on group companies located in Italy that are subject to low taxation.
Filing requirements
Under Legislative Decree no. 209/2023, obligated entities must submit an annual declaration to the Revenue Agency containing the data necessary to determine the amounts due for the three tax types.
The declaration must be filed electronically, either by the taxpayer or an authorised representative, with the launch date of the online filing system to be announced later by the tax authorities.
The directive approves the declaration form, accompanying instructions, and transmission methods. Declarations must be filed exclusively through electronic channels, either directly or through authorised representatives registered with the Agency’s online services.
The Revenue Agency has made the free “DichiarazioneGlobe” software available for preparing submissions, which is available for download from its website. The opening date for the electronic filing channel will be announced separately on the Agency’s website, while technical specifications for file transmission will be defined in a subsequent provision.
The global minimum tax return form and its instructions were approved under Protocol No. 46523/2026 of 6 February 2026.
Filing and payment deadlines
The tax return deadline is 15 months after the fiscal year ends, extended to 18 months for the first year, with the earliest possible deadline being 30 June 2026. Returns must be filed electronically through the Tax Agency’s system or via an authorised intermediary.
Payment occurs in two instalments: 90% of the total tax due within 11 months after the fiscal year ends, and the remaining 10% within one month after the return deadline.
Payments must be made using Italy’s F24 form with specific tax codes outlined in the instructions.
