Portugal’s Tax and Customs Authority had opened the electronic filing service for 2024 Form 64 under the Global Minimum Tax Regime, with the service covering Portuguese constituent entities subject to Pillar Two rules.
Portugal’s Tax and Customs Authority has opened the electronic submission service for Form 64 – Settlement Declaration of RIMG/Pillar Two for fiscal year 2024, under Article 45(1)(c) of Law No. 41/2024, the Global Minimum Tax Law.
The authority issued the notice on 23 September 2026, confirming that the filing service is available for Portuguese constituent entities subject to the Global Minimum Tax Regime (RIMG).
Filing deadline
Form 64 generally applies to each constituent entity in Portugal that belongs to an MNE group within the scope of the RIMG. A local entity may instead be designated to file the declaration on behalf of all Portuguese entities in the group.
The standard filing deadline is 15 months after the end of the fiscal year, with an 18-month period applying for the first year. Portugal has, however, extended the deadline to 30 September 2026 for constituent entities whose fiscal years ended between 31 December 2024 and 31 March 2025.
Global Minimum Tax Regime
Law No. 41/2024 of 8 November, transposed Council Directive (EU) 2022/2523 into Portuguese domestic law and established the RIMG, implementing OECD Pillar Two rules.
The regime applies to MNE groups and large-scale domestic groups meeting the EUR 750 million consolidated revenue threshold in at least two of the four preceding fiscal years. It seeks to ensure a minimum global effective tax rate of 15%.
The RIMG includes three top-up tax mechanisms: the Portuguese Qualified Domestic Minimum Top-Up Tax (ICNQ-PT / QDMTT), the Income Inclusion Rule (IIR) and the Undertaxed Profits Rule (UTPR).
Reporting requirements
Portuguese constituent entities, or designated local entities, are required to submit a GloBE Information Return (GIR) and the relevant top-up tax settlement return to the AT electronically.
The RIMG also provides for penalties for non-compliance. Failure or delay in submitting required returns may result in fines ranging from EUR 5,000 to EUR 100,000, with an additional 5% increase per day of delay. Omissions or inaccurate statements may attract fines ranging from EUR 500 to EUR 23,500.
The submission service is available through the AT under the designation “Form 64 – Settlement Declaration of RIMG/Pillar Two.
