The Revenue Agency issued expanded GMT guidance on 17 July 2026 clarifying penalties under Legislative Decree no. 472 of 1997, including a 90-day window for late returns before full penalties apply, a three-year grace period waiving sanctions and confirmation that multinational groups can file their GloBE Information Return centrally if their home jurisdiction has a functioning portal and "Qualified Agreements" with all operating countries.
The Italian Revenue Agency has published a new FAQ on the Pillar Two Global Minimum Tax (GMT) on 17 July 2026, expanding on the guidance first issued on 29 May 2026.
While the original FAQs covered topics such as reporting obligations, safe harbour application, and currency standardisation, the latest FAQ clarifies the penalties for failing to meet GMT filing obligations, including the GMT notification, the GloBE Information Return (GIR), and the GMT return. It also explains how late filing may affect eligibility for safe harbours, including the Transitional Country-by-Country Reporting (CbCR) safe harbour.
Key points include:
Italy’s “ravvedimento operoso” mechanism lets taxpayers correct late or inaccurate tax submissions and reduce or eliminate the corresponding penalties. This voluntary disclosure route, governed by Article 13 of Legislative Decree no. 472 of 1997, applies across multiple filing obligations—but timing and what is being corrected determine how much penalty relief actually applies.
Tax returns: the 90-day cutoff matters
If a tax return is filed late, recovery is still possible—but only within a 90-day window. Under Article 2, paragraph 7 of Presidential Decree No. 322 of 1998, penalties for a tardy return can be reduced if Article 13 of the 1997 decree is invoked and the submission is made within those 90 days.
File after day 90, and tax authorities treat the return as omitted entirely. At that point, the voluntary disclosure mechanism no longer applies, and the full penalty stands.
Incorrect returns, however, follow different rules. Taxpayers can voluntarily amend them regardless of how late they are, and the penalty reduction still kicks in.
Early-stage grace period: no penalties for three years
For the first three years, after these rules go into effect, the system includes a safety net. Sanctions are off the table entirely—except if there is evidence of fraud or gross negligence (Article 53, paragraph 5 of the Legislative Decree). This means even incomplete or incorrect filings can be corrected penalty-free during this initial window.
Communications and notifications: 50% penalty cuts apply
Late submission of Relevant Communications and notification forms falls under Article 51, paragraph 9. Again, Article 13’s voluntary disclosure rules apply, but there is a bonus for early adopters. During the first three years, administrative penalties for these violations are automatically cut by 50%. After those three years, the full penalty applies unless the voluntary disclosure route is used.
Options declared in late communications stay valid
Submitting a Relevant Communication late does not invalidate the options elected inside it—including the Simplified Transitional Regime or Transitional CbCR Safe Harbour. The law contains no forfeiture provision for these elections, meaning the benefit is retained even if the paperwork arrived behind schedule. What changes is only the penalty exposure, not the substantive choice itself.
Making the payment
When filing a voluntary disclosure, taxpayers must use the specific tax codes the Revenue Agency will announce by resolution. The codes are not set yet, so the announcement should be monitored before payment is made.
Centralised GloBE filing rules for multinational groups
In addition, the Revenue Agency also issued guidance on 22 June 2026 clarifying how groups can use a centralised system to file their GloBE Information Return (GIR) rather than submitting separately in each country.
The filing obligation itself stems from Article 8.1 of the OECD Model Rules, with the framework last updated through Administrative Guides in January 2025 (revised January 2026).
The centralised route reduces administrative load significantly, but it comes with a condition: The home jurisdiction must have both a functioning digital portal and a “Qualified Agreement” in place with every country where the group operates. Without those bilateral arrangements, authorities cannot share the data, and local filing remains necessary.
The guidance responds to a rocky initial rollout. On 18 May, the OECD and participating countries agreed on a common fix, and Italy’s June document translates that operational compromise into concrete steps for Italian groups navigating the 15% Global Minimum Tax regime.
