The Italian tax authority has unveiled digital tools enabling multinational groups to comply with new global minimum tax obligations, with submissions opening in spring 2026 for both notification forms and annual returns. 

RF Report

The Italian Revenue Agency has introduced new software to facilitate compliance with the Pillar Two global minimum tax framework, marking a significant step in implementing the OECD’s international tax reforms.

Companies subject to the supplementary tax rules must now navigate two distinct filing obligations.

The first is a notification form that designates which group member will handle the GloBE Information Return, known locally as the Comunicazione Rilevante.

The second requirement is the global minimum tax declaration itself, termed the Dichiarazione Fiscale GloBE. Software for the global minimum tax declaration has also been released.

Both filing systems will become operational from 31 March 2026. Importantly, in-scope group members must submit the tax return for any fiscal year falling under Pillar Two regulations, even when no actual tax liability arises.

Italy’s Legislative Decree No. 209, enacted on 27 December 2023, introduced a three-tiered minimum tax system targeting multinational and national business groups. The framework includes a supplementary minimum tax for Italian parent companies with low-taxed subsidiaries, another supplementary tax for Italian entities when foreign jurisdictions fail to apply equivalent levies, and a national minimum tax for undertaxed Italian group members.

Article 53 mandates annual returns for all three tax types, with the Deputy Minister of Economy and Finance formalising the compliance and payment procedures through a decree on 7 November 2025.