Qualifying entities subject to the top-up tax must file the minimum tax return electronically within 15 months of the fiscal year-end, extended to 18 months for the transitional first year, with no deadline earlier than 30 June 2026.
Italy’s revenue agency has announced, on 10 November 2025, that the Ministry of Finance’s Decree of 7 November 2025 has been issued, establishing 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).
Deadlines and filing rules
The declaration must be sent to the Revenue Agency within the same timeframe as the “Relevant Communication”—that is, within 15 months after the close of the financial year.
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.
How the tax is paid
The tax is settled in two parts:
- First instalment: 90% of the total, due by the 11th month after the year-end. For a company whose 2024 financial year matches the calendar year, the deadline becomes 1 December 2025 (because 30 November is a Sunday).
- Second instalment: the remaining 10%, due within one month of the tax return filing deadline. In the same example, this means payment by the end of July 2026.
With Resolution No. 63/E of 10 November 2025, the Revenue Agency introduced the payment codes and explained how to complete the F24 form.
If a company pays more than required, the excess can be carried forward to reduce the same tax in later years or requested as a refund. Horizontal offsetting with other types of taxes is not allowed.
Penalties and liability
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.
The Revenue Agency’s Director will issue a further measure approving the official tax return form, related instructions, and the technical rules for electronic submission.
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.
