The 7 November 2025 Decree sets filing and payment rules for the global minimum tax, covering IIR, UTPR, and QDMTT.
Italy’s government has published the Decree of 7 November 2025 from the Ministry of Finance in the Official Gazette on 10 November 2025.
The Decree of 7 November 2025 establishes the filing and payment requirements for the global minimum tax, including the Income Inclusion Rule (IIR), the Undertaxed Profit Rule (UTPR), and the Qualified Domestic Minimum Top-up Tax (QDMTT).
For the first year in which the new rules apply, this window is extended to 18 months. In any case, no first filing will be due before 30 June 2026.
All entities subject to the obligation must keep the accounting and non-accounting documents used to prepare the return. These must be shown to the tax authorities if requested and preserved until the retention period.
The first deadline is 30 June 2026 or later. Tax is paid in two instalments: 90% within 11 months after the financial year-end, and the remaining 10% within 1 month after the return deadline.
Failure to file or pay triggers the sanction system contained in Legislative Decrees 471 and 472/1997. However, for the first three financial years of application of Legislative Decree 209/2023, no administrative penalties will apply unless there is intent or gross negligence. Companies and group entities for which the reporting entity acts are jointly and severally liable for the tax, interest, and penalties.
Earlier, Italy’s revenue agency announced that the Ministry of Finance had issued guidelines for completing the Pillar 2 GloBE Information Return (GIR) model form on 3 November 2025.
