Italy's tax administration aligned with OECD guidance on 22 June 2026 to allow multinational groups to file Global Minimum Tax returns centrally through a single designated entity in any of 33 jurisdictions, temporarily exempting Italian entities from local filing if data is exchanged by 31 December 2026; updated FAQs clarify rules for mid-year ownership changes and liquidated funds.
The Italian Ministry of Economy and Finance and the Revenue Agency have published coordinated guidance on Global Minimum Tax reporting, including centralised filing procedures for the GloBE Information Return and comprehensive FAQs addressing Pillar Two compliance obligations.
Centralised GIR filing framework
The Ministry of Economy and Finance has issued guidance on 22 June 2026 pertaining to the centralised filing of the GloBE Information Return (GIR) in line with the Common Understanding released by the OECD in May 2026. The directive establishes standardised procedures for multinational enterprises meeting Pillar Two reporting thresholds. The directive also details a common understanding reached by 33 jurisdictions to simplify compliance for multinational groups by allowing a single reporting entity to submit tax data, which is then shared via automatic information exchange.
The guidance confirms that Italy actively supports the “central filing” mechanism to reduce administrative burdens for multinational groups. Italy will accept a single filing made by an Ultimate Parent Entity (UPE) or a designated filing entity in another jurisdiction.
Italian entities are temporarily relieved of local filing obligations if they participate in this centralised filing. If the Italian Revenue Agency does not receive the exchanged data from the foreign jurisdiction by 31 December 2026, the provisional exemption is lifted. In that scenario, the local entities must submit a local filing within one month (30 days) of receiving a formal request from the Revenue Agency.
In case of non-compliance, administrative financial penalties will apply if the requested local filing is submitted beyond the 30-day deadline or contains erroneous data.
For Italy to honour the centralised filing, the filing must take place in one of the 33 jurisdictions that signed the OECD’s “Common Understanding” (which are expected to have portals ready by 31 May 2026) or in Cyprus. The guidance makes a special point to clarify that Cyprus is uniquely accommodated; despite not being part of the OECD Inclusive Framework, it has adopted a qualifying IIR and is bound by EU directive DAC 9 to exchange information.
Updated FAQ resource on compliance issues
The Italian Revenue Agency expanded its support infrastructure by publishing two new FAQs addressing Pillar Two Global Minimum Tax matters. The updated Pillar Two FAQs, originally released on 29 May 2026, now cover critical operational areas including reporting obligations, safe harbour application, currency standardisation, and related compliance considerations.
The first question concerns an Italian company sold in 2024 from a multinational group to another group. The Italian Revenue Agency clarified that when an Italian company changes ownership between multinational groups during a tax year, it must file separate national minimum tax returns for each group to which it belonged.
However, both returns must indicate the full group tax period—from 1 January to 31 December 2024—as the reference year. The Agency confirmed that a mid-year change in group membership does not require the fiscal year to be divided into separate reporting periods on the return’s title page.
The second question refers to an Italian investment fund that was liquidated in 2025 after being managed by an Italian asset management company (AMC).
The Italian Revenue Agency confirmed that, for Global Minimum Tax reporting purposes, the liquidated fund may use the AMC’s tax code instead of obtaining a separate tax code or new tax identification number. However, the return must still identify the fund by name rather than the management company. The Agency also clarified that this simplification is available only where no other funds managed by the same AMC are included in the same return, as each tax code can be linked to only one entity in the relevant sections of the declaration.
