The first GloBE Information Returns (GIRs) under the EU Minimum Tax Directive (2022/2523) were due by 30 June 2026 in most EU jurisdictions, but several Member States have announced extensions that alter the effective filing calendar for groups with consolidated annual revenue of EUR 750 million or more. France, Portugal and Belgium have each published formal measures pushing their respective deadlines into the third quarter of 2026, and Italy has issued guidance on central filing and local fallback obligations. International groups operating across the EU should assess their exposure without delay, as non-compliance carries both direct tax risk and reputational consequences.
Background: What Changed and Why It Matters Now
Council Directive (EU) 2022/2523, which transposed the OECD Pillar Two Global Anti-Base Erosion (GloBE) rules into EU law, requires in-scope groups to calculate, report and – where applicable – pay a top-up tax to bring their effective tax rate up to the agreed global minimum. The first fiscal year to which these obligations apply in most EU Member States is FY2024, making 2026 the year in which the compliance machinery faces its first real operational test.
Two significant developments have shaped the landscape in early 2026. On 5 January 2026, the OECD/G20 Inclusive Framework approved the Side-by-Side package, introducing UPE safe harbours, simplifications and revised treatment of substance-based incentives. On 12 January 2026, the European Commission published Notice C/2026/253, confirming how that package applies under the Directive. Groups that built their FY2024 compliance models before these publications should verify whether their positions remain current. A further development occurred on 11 September 2026, when the OECD released an updated GIR form applicable to fiscal years beginning on or after 31 December 2025 – an update that affects filing format planning for FY2025 cycles already underway.
Effective tax risk management in this environment requires tracking not only the central OECD and EU-level rules but also the patchwork of national implementing measures, extensions and guidance notes that have emerged in rapid succession.
Who Is Affected in the European Union
The Directive applies to constituent entities of multinational enterprise (MNE) groups and large-scale domestic groups whose consolidated annual revenue equals or exceeds EUR 750 million in at least two of the four fiscal years immediately preceding the tested fiscal year. This threshold mirrors the Country-by-Country Reporting threshold, so groups already subject to CbCR obligations will generally fall within scope.
Within an MNE group, the filing obligation can be discharged by a single designated filing entity on behalf of all constituent entities – a mechanism the OECD refers to as the central GIR. However, where no central filing arrangement is in place, or where exchanged data do not arrive within the prescribed timeframe, constituent entities in each Member State may face local filing obligations. Groups with complex holding structures, joint ventures or partially owned entities should pay particular attention to how constituent entity status is determined under national rules.
Transfer pricing arrangements and substance-based incentive structures may also interact with the GloBE calculations in ways that affect the effective tax rate computation. Groups engaged in active tax structuring should ensure that existing structures have been stress-tested against the GloBE rules, including the updated Side-by-Side package, before finalising their first returns.
Key Deadlines: The 30 June 2026 Baseline and National Extensions
The table below summarises the filing positions in the jurisdictions for which confirmed information is available as of the date of this alert.
| Jurisdiction | Standard / Extended Deadline | Scope and Conditions | Authority / Reference |
|---|---|---|---|
| Most EU jurisdictions | 30 June 2026 | First GIR for FY2024 (general rule) | Directive 2022/2523; national implementing acts |
| Portugal | 30 September 2026 (without additions or penalties) | Constituent entities with fiscal years ending between 31 December 2024 and 31 March 2025; Pillar Two declarations only – the registration declaration is not covered | Order 76/2026-XXV of 3 June 2026 |
| France | 1 September 2026 | First GIR, GloBE tax return and payment of top-up tax | French tax authority announcement, 8 July 2026 |
| Belgium | 30 September 2026 | GIR notification | National guidance (details subject to national rules) |
| Italy | 30 June 2026 (central filing); local fallback within one month after 31 December 2026 | Central filing permissible through a designated entity in an exchanging jurisdiction; if exchanged data not received by 31 December 2026, Italian entities must file locally within one month | Ministry of Economy and Finance guidance, 22 June 2026 |
Groups operating in Member States not listed above should treat the 30 June 2026 baseline as operative unless they have received written confirmation of an extension from the relevant national authority. Relying on informal signals or third-party summaries without verifying the primary source creates unnecessary tax audit exposure.
If you need to clarify the filing position in a specific Member State, our team can assist. Contact us at info@ferrazwhitmore.com or visit our contacts page.
Italy: Central Filing, Exchange of Information and the Local Fallback
Italy's approach deserves specific attention because it introduces a two-stage mechanism with a hard backstop. Under the Ministry of Economy and Finance guidance of 22 June 2026, an Italian constituent entity may rely on a central GIR filed by a designated entity located in a jurisdiction that participates in the automatic exchange of GloBE information. The standard filing deadline for this central route remains 30 June 2026.
The critical contingency arises if Italian tax authorities do not receive the exchanged data by 31 December 2026. In that event, each Italian constituent entity must file locally within one month of that date. Groups that have opted for a centralised filing structure must therefore maintain a clear audit trail showing when the central filing was made and in which exchanging jurisdiction, and must be operationally ready to initiate local filings on short notice if the exchange mechanism does not function as expected. This contingency planning sits squarely within broader anti-avoidance rules compliance and governance frameworks.
Interaction with the OECD Side-by-Side Package and Updated GIR Form
The Side-by-Side package approved on 5 January 2026 and confirmed at EU level by Commission Notice C/2026/253 introduces several technical changes that affect FY2024 calculations, including new UPE safe harbour conditions and adjustments to how substance-based income exclusions interact with certain incentive regimes. Groups should not assume that a GloBE model built before 5 January 2026 fully reflects these changes.
The updated GIR form released by the OECD on 11 September 2026 applies to fiscal years beginning on or after 31 December 2025. While this does not alter the FY2024 filing obligation directly, it is material to groups now planning their FY2025 compliance cycle. Firms with non-calendar fiscal years that straddle this date should obtain specialist advice on which form version applies to them.
For groups with holding entities or intermediate structures in EU jurisdictions where the interaction of tax treaty networks and GloBE top-up tax remains unsettled, the guidance landscape is still evolving. Questions concerning treaty override, the application of European Commission state aid rules to qualified domestic minimum top-up taxes, and potential referrals to the CJEU have been raised in academic and practitioner commentary; definitive positions from most Member States are pending.
Immediate Action Items for International Companies
Given the convergence of the 30 June 2026 baseline deadline, national extensions and the publication of new technical guidance, the following steps merit priority attention:
- Map your filing obligations jurisdiction by jurisdiction. Identify every EU Member State in which your group has constituent entities and confirm whether a national extension applies, its precise scope and any conditions (such as Portugal's exclusion of the registration declaration).
- Verify your central filing arrangements. If you are relying on a centralised filing through a designated entity, confirm that the chosen jurisdiction participates in the relevant exchange mechanism and that the filing was or will be submitted before the applicable deadline.
- Review your GloBE model against the Side-by-Side package. Commission Notice C/2026/253 confirms that the 5 January 2026 OECD package applies under the Directive; recalculations may be required for FY2024 before returns are filed.
- Prepare for the FY2025 cycle now. The updated GIR form for fiscal years beginning on or after 31 December 2025 was published on 11 September 2026; incorporate it into your compliance calendar. Our Pillar Two compliance calendar for the EU provides a structured overview of upcoming dates.
- Assess governance and documentation. Tax authorities across the EU are developing tax audit methodologies for GloBE returns. Robust contemporaneous documentation of data sources, calculation methodologies and filing decisions reduces exposure significantly.
Corporate governance obligations connected to Pillar Two compliance may also engage corporate law considerations, particularly for entities with board-level reporting duties or listed companies subject to ESMA and EBA disclosure frameworks. Ensuring that finance, tax and legal functions are aligned on these obligations is a practical priority for group compliance officers.
For a preliminary review of your group's EU filing position, please reach out to our team at info@ferrazwhitmore.com or use our contacts page. We can assist with jurisdiction mapping, review of central filing documentation and coordination across multiple EU Member States.
Sources
- Irish Revenue – Pillar Two key dates: revenue.ie
- OECD Pillar Two Developments Tracker 2026: oecdpillars.com
- Deloitte tax@hand – France Pillar Two: first GIR filing deadline extended: taxathand.com
- RegFollower – Italy updates Pillar Two guidance with GIR filing rules and FAQs: regfollower.com
Facts last verified: 22 September 2026.
Disclaimer: This publication is provided for informational purposes only and does not constitute legal advice. The information herein should not be relied upon as a substitute for professional legal counsel tailored to your specific circumstances. Ferraz & Whitmore assumes no liability for actions taken or not taken based on the contents of this material. For advice regarding your particular situation, please contact info@ferrazwhitmore.com.