The form must generally be submitted within 15 months of the fiscal year-end, with an extended deadline of 18 months for the first reporting year.
Italy’s revenue agency has announced that the Ministry of Finance has issued guidelines for completing the Pillar 2 GloBE Information Return (GIR) model form (Comunicazione Rilevante on 3 November 2025.
This follows the approval of the form under the Decree of 16 October 2025, which was published in the Official Gazette on 29 October 2025, outlining obligations related to Pillar 2 reporting. The decree defines key terms and sets out rules for multinational and large domestic groups in Italy regarding tax reporting and notification obligations.
According to the guidelines, the form must generally be submitted within 15 months of the fiscal year-end, with an extended deadline of 18 months for the first reporting year.
The interpretative directive of 30 October briefly describes the three sections that make up the standard Relevant Communication form and provides operational clarifications on the information and data to be included in the respective tables of the form.
Section 1: Information on the multinational or domestic group of companies
The first section provides a comprehensive overview of the structure and accounting information relating to the group subject to the Globe rules. The personal and identification data of the entity submitting the relevant communication (Declaring Company) are required. This section also includes the identification of the Parent Company, the applicable tax period, and the accounting principle used to prepare the consolidated financial statements (e.g., IFRS, US GAAP, etc.).
A “Summary Sheet” is available, containing high-level information on the application of the rules for each country. The summary shows the range of the calculated Effective Tax Rate (ETR) and indicates the amounts due as supplementary tax or national minimum tax/equivalent, broken down by amount bracket.
Section 2: Simplified regimes and jurisdictional exclusions
The second section provides evidence of the situations in which the group does not have to pay or calculate the top-up tax thanks to special or simplified regimes, temporary or permanent.
This section should, for example, indicate the use of simplified transitional regimes (Safe Harbour), which allow, under certain conditions, the avoidance of detailed ETR and supplementary tax calculations for countries deemed to be low-risk. This section should also indicate the jurisdictions excluded from the calculation of the supplementary tax, as they include groups with significant net revenues and profits below specific thresholds.
The Declaring Company must send this section to the tax administration of the country of the parent company, or to the administration of the country that exercises taxing rights over the country for which the exceptions apply. In particular, if a country applies an equivalent national minimum tax (Qdmtt), the section must be sent to the tax administration of that country.
Section 3: Calculations
The third section is the most technical and documents the calculations that allow us to determine, for each jurisdiction or subgroup, in which the exceptions already indicated in Section 2 do not apply, the Effective Tax Rate (ETR) of the group and the “top-up tax” if the ETR is lower than the minimum threshold of 15%.
The guidelines indicate that the section contains, among other things, the numerical data (relevant income, relevant taxes, etc.) necessary to calculate the ETR in each jurisdiction, as well as the calculation of the national minimum tax/equivalent for the jurisdiction, where applicable.
Section 3 includes, for each jurisdiction/subgroup: relevant income, taxes paid or due, calculation of the effective tax rate (ETR), calculation of the top-up tax, and any adjustments. The methodology followed for any adjustments (for example: elimination of intra-group revenue, tax losses carried forward, tax credits) and the reporting of regulatory differences compared to OECD standards are also required.
