Applying to multinational and domestic groups with annual revenues of at least EUR 750 million, the rules cover the IIR, UTPR, and QDMTT, with returns submitted in XML format and the first filing deadline no earlier than 30 June 2026.
The Italian Revenue Agency has issued an Order (Provision), on 8 April 2026, approving the technical specifications for the electronic filing of the annual global minimum tax return, covering top-up tax obligations under the Income Inclusion Rule (IIR), the Undertaxed Profits Rule (UTPR), and the Qualified Domestic Minimum Top-up Tax (QDMTT).
The Revenue Agency also published the Order of 9 April 2026, which approves the schema and procedures for submitting the annual minimum tax return covering top-up taxes under Legislative Decree No. 209/2023.
The Order of 8 April 2026: Technical specifications for the tax return
This Order details the requirements for the Information Return, including submission deadlines, electronic formats, and procedures for the automatic exchange of information with other tax authorities. It specifies that multinational and national groups with annual revenues exceeding EUR 750 million must comply with these transparency measures.
This return covers the top-up taxes mandated by Legislative Decree No. 209/2023, specifically:
- Income Inclusion Rule (IIR)
- Undertaxed Profit Rule (UTPR)
- Qualified Domestic Minimum Top-up Tax (QDMTT)
The data must be submitted according to the specifications in Annex A of the order, following the model previously approved on 6 February 2026.
The Order of 9 April 2026: The GloBE Information Return (GIR)
This order establishes the procedures and schema for the GloBE Information Return. This return is designed to fulfil the information obligations required by DAC9 (Directive (EU) 2025/872) and the Ministerial Decree of 16 October 2025. This Order details specific submission deadlines, such as the 15th month following the fiscal year-end, and mandates the use of XML formatting via official digital channels.
Furthermore, the text outlines the automatic exchange of information between international tax authorities to ensure global compliance and administrative cooperation.
The Order of 9 April 2026 consists of a general section and one or more jurisdictional sections containing data necessary to determine the top-up tax due by a multinational or national group. It applies to Italian-located entities belonging to groups with annual revenues of at least EUR 750 million in at least two of the four preceding fiscal years.
Generally, the return must be submitted within 15 months after the end of the fiscal year. For the
Transition Year, this is extended to 18 months. Crucially, for the first submission, the deadline cannot be earlier than 30 June 2026.
Entities must use the Agency’s Entratel or Fisconline services to submit the data in XML format.
The Italian Revenue Agency will exchange this information with other EU Member States and jurisdictions under qualifying agreements within three months of the filing deadline (extended to six months for the first year). The first exchange of information will not occur before 1 December 2026.
Corrective communications for errors reported by foreign competent authorities must be filed within 30 days of receiving notice from the Italian Revenue Agency. Failure to comply with these filing requirements may result in penalties as established by Legislative Decree No. 209/2023.
