Portugal has adopted the official GloBE Information Return (GIR) through Ordinance No. 255/2026/1, setting out the reporting requirements for entities subject to the global minimum tax regime. The measure implements the reporting framework under EU Directive 2022/2523 and details filing procedures, jurisdictional tax calculations, safe harbour provisions, and top-up tax reporting obligations.

RF Report

Portugal has published Ordinance No. 255/2026/1 in the Official Gazette on 12 June 2026, approving the official GloBE Information Return (GIR) for the country’s global minimum tax regime. The ordinance adopts the standardised GIR form and establishes the reporting framework for entities required to comply with the global minimum tax rules.

This regulation transposes EU Directive 2022/2523, ensuring a minimum tax level for multinational enterprise (MNE) groups and large-scale domestic groups.

Compliance and filing procedures

  • Submission method: The declaration must be submitted electronically via an XML file through the Portuguese Tax and Customs Authority (AT) website (Portal das Finanças).
  • Language requirements: The official Model 63 form is in Portuguese. However, the instructions for completion are based on the standards published by the OECD/G20 Inclusive Framework, and both the original OECD version and the Portuguese translation are available for guidance.

Filing types:

  • Local Filing: Standard presentation to the Portuguese tax authority.
  • Central Filing: A derogation allows the return to be filed by the Ultimate Parent Entity (UPE) or a designated filing entity in another jurisdiction, provided a “qualifying competent authority agreement” for the automatic exchange of information is in place. EU Directive 2025/872 serves as such an agreement between Member States.
  • Effective date: The regulation entered into force immediately following its publication in June 2026.

Structure of the GIR (Model 63)

The return is highly detailed and divided into several sections to capture the group’s global tax footprint:

  1. Group identification and structure
  • Constituent entity info: Identification of the reporting entity, its role (e.g., parent or designated filer), and its Tax Identification Number (NIF).
  • MNE group overview: Name of the group, reporting fiscal year, consolidated financial statement type, and the accounting standards used (e.g., IFRS).
  • Corporate mapping: Detailed list of all constituent entities, joint ventures, and excluded entities, including their jurisdictions, NIFs, and ownership percentages.
  1. High-Level Summary and Safe Harbors
  • Jurisdictional overview: A summary for each jurisdiction where the group operates, indicating the applicable effective tax rate (ETR) range and the amount of top-up tax due.
  • Safe harbors: Documentation for entities opting for simplified calculations, such as those for “immaterial constituent entities,” or transitional safe harbors based on Country-by-Country Reporting (CbCR).
  • Exclusions: Options for the de minimis exclusion (where income and profits fall below certain thresholds).
  1. Detailed calculations (ETR and Top-up Tax)
  • Adjusted covered taxes: Calculations for taxes paid, including adjustments for deferred taxes, uncertain tax positions, and credits.
  • GloBE income or loss: Determination of the net income for each jurisdiction, including adjustments for excluded dividends, equity gains/losses, and pension costs.
  • Substance-based Income exclusion: Calculations for exclusions related to payroll costs and tangible assets.
  • Top-Up tax calculation: The final determination of the jurisdictional top-up tax percentage and the resulting tax amount due, including the application of the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR).
  1. Special adjustments and transitional rules
  • Specific regimes: Provisions for international shipping income exclusions and special distribution tax regimes.
  • Transitional provisions: Rules governing the transfer of assets before entering the regime and the recalculation of deferred tax assets/liabilities at the minimum 15% rate.

Earlier, Portugal’s Tax and Customs Authority has published Order No. 76/2026-XXV of 3 June 2026, extending the deadline for submitting the GloBE Information Return (GIR) and the top-up tax settlement required under Article 45(1)(b) and (c) of Law No. 41/2024, the Global Minimum Tax Law.