Italy has joined an international agreement allowing multinational corporations to file Global Minimum Tax returns through a centralised system, avoiding penalties despite portal delays. The OECD arrangement, published on 18 May 2026, involves 33 countries and provides conditional relief until 31 December 2026.
The Italian Ministry of Finance confirmed, on 19 May 2026, that Italy has joined the common understanding on GloBE Information Return filing under Pillar Two.
Countries implementing the Global Minimum Tax from 2024 onwards, including Italy, have adopted a unified approach to preserve the efficiency benefits of centralised GIR submissions. This collaborative framework aims to simplify compliance procedures for multinational enterprises while ensuring consistent reporting standards across participating jurisdictions.
The arrangement addresses practical challenges that nations face in establishing technical infrastructure to receive tax returns and in setting up information exchange mechanisms between tax authorities. By agreeing on common procedures, member countries can move forward with implementation despite varying timelines for completing their domestic systems.
Earlier, the OECD published the interpretation document on 18 May 2026, along with updates to the Central Register and new guidance on transitional Safe Harbour rules for the Income Inclusion Rule and Undertaxed Profits Rule.
The common understanding offers penalty waivers for companies using centralised GIR filing systems, provided the return is submitted to any qualifying jurisdiction by the deadline, and a local notification is filed.
However, jurisdictions retain the right to enforce local filing requirements and impose penalties if the centrally filed GIR is not properly exchanged between tax authorities by 31 December 2026.
The agreement includes 33 jurisdictions expected to have operational GIR portals by 31 May 2026: Australia, Austria, Barbados, Belgium, Bulgaria, Canada, Croatia, Czechia, Denmark, Finland, France, Germany, Gibraltar, Greece, Hungary, Ireland, Italy, Japan, Korea, Liechtenstein, Luxembourg, the Netherlands, Norway, Poland, Portugal, Romania, Slovenia, South Africa, Spain, Sweden, Switzerland, Türkiye, and the United Kingdom.
