Portugal has granted a three-month extension for the first filings under its Global Minimum Tax Regime, while also confirming that Cyprus must be treated as having a qualified Income Inclusion Rule for Pillar Two purposes across the EU.
Portugal’s Tax and Customs Authority has published Order No. 76/2026-XXV of 3 June 2026, extending the deadline for submitting the GloBE Information Return (GIR) and the top-up tax settlement required under Article 45(1)(b) and (c) of Law No. 41/2024, the Global Minimum Tax Law.
Under the order, constituent entities whose fiscal year ended between 31 December 2024 and 31 March 2025 will have until 30 September 2026 to submit both returns for the 2024 tax year. The previous deadline for entities with a 31 December 2024 year-end was 30 June 2026.
The extension applies to multinational enterprise groups and large domestic groups subject to Portugal’s Global Minimum Tax Regime. According to the government, the additional time reflects the complexity of collecting, validating and coordinating tax information across groups during the first year of implementation.
Portugal also cited a common understanding issued by the OECD on 18 May 2026, under which jurisdictions implementing Pillar Two may waive penalties or defer local GIR filing obligations where difficulties arise in making filing systems available or operationalising information exchange arrangements. The Portuguese authorities indicated that the extension aligns with this approach.
Separately, the Tax and Customs Authority issued guidance following a European Commission FAQ concerning the status of Cyprus under the Pillar Two framework.
The Commission clarified that, for the purposes of the Pillar Two Directive, the qualified status of the Income Inclusion Rule (IIR) implemented by Cyprus derives directly from Article 3(18) of the Directive for fiscal years beginning on or after 31 December 2023. As a result, all EU Member States must treat Cyprus as having a qualified IIR in force, even though Cyprus does not currently appear in the OECD Central Record of legislation with qualified status.
The FAQ further states that Cyprus may receive GloBE Information Returns from 31 May 2026 and must exchange information with other Member States under Directive DAC9 within the deadline for the first mandatory exchange.
Consequently, where a multinational enterprise group chooses to file its GIR centrally in Cyprus, other EU Member States, including Portugal, must not require local filing of the same return, in accordance with Directive DAC9. This treatment applies regardless of Cyprus’s current absence from the OECD’s list of jurisdictions with recognised qualified status.
Earlier, Portugal published Law No. 26/2026 of 3 June 2026, implementing the exchange of information relating to the global minimum tax regime.
